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87 <br />D. Tiering. CEQ's NEPA regulations (40 CFR 1502.20) encourage tiering <br />EISs. Tiering, however, is not a substitute for the adequate assessment of <br />sitespecific environmental effects. For example, a programmatic EIS must <br />consider cumulative, direct, and indirect impacts; however, this may result <br />in less detailed assessments of impacts than would be addressed on a site- <br />specific EIS. <br />E. Discussion of Inconsistencies with State and Local Plans. <br />CEQ's NEPA regulations~j40~CFR 1506.2(d)] require an EIS to discuss any <br />inconsistencies the proposed action may have with an approved State or <br />local plan or law, and to address the extent to which the lead agency plans <br />to reconcile its proposed action with the plan or law. Service comments on <br />EISs should address key .State and local planning efforts which have Service <br />involvement in development, review, and/or approval. Some of these are <br />listed below. <br />(1) Management and habitat acquisition plans funded by Dingell-Johnson <br />(D-J) :and Pittman-Robertson (P-R), Land and Water Conservation Act, <br />section 6 (Endangered Species Act) cooperative agreements, or through other <br />grant programs. <br />(2) Coastal Zone Management Plans. <br />(3) State and local wetland and floodplain management plans. <br />(4) Coastal Barriers Resources Act, as amended. <br />(5) .Habitat conservation planning under section 10(a)(1)(B), recovery plans, <br />and recovery actions, pursuant to the Endangered Species Act. <br />(6) State water quality standards. <br />F. Service Reviews should be Total and Comprehensive. <br />(1) EIS reviews should include consideration of total, long-term <br />ecological impacts, including any direct and secondary (or indirect) <br />impacts. Also, Service reviewers should consider any cumulative effects, <br />or possible project segmentation which could mask cumulative effects. <br />(2) The Service should provide consistent positions. Do not contradict <br />earlier statements unless project alternatives, impacts, or conditions have <br />substantially changed; or significant new data are available. Any <br />significant change in Service position must be substantiated (justified) in <br />writing. <br />(3) Service reviews must represent the views of all Service program areas. <br />Any uncompleted or unresolved reviews or consultations under other statutes <br />must be indicated/summarized in the Service's comments. <br />3.4 Comments on Draft EISs. The Service should review and comment on an <br />agency's draft EIS to ensure that fish and wildlife resources are <br />adequately considered in their programs and plans. A sample DOI letter <br />