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<br />HOW TO DEFINE REASONABLE ALTERNATIVES <br /> <br />The environmental impact <br />statement (EIS) process requires the <br />analysis of reasonable alternatives <br />to make the document as useful as <br />possible. <br /> <br />There are no magic rules or <br />standards for determining which <br />concepts or alternatives are <br />reasonable for detailed analysis in <br />an EIS. Such determinations are <br />usually based on available <br />information and professional <br />judgement. According to Bob <br />Moeller (001 Solicitor's Office), <br />"Often there may be differing views <br />and considerable subjectivity on <br />what constitutes the notion of <br />reasonableness. It is important to <br />consider all aspects and document <br />the determinations made in the <br />administrative record, which will be <br />created for the EIS and the Record of <br />Decision." Alternatives judged to be <br />reasonable will be subjected to <br />detailed analysis and others <br />determined not reasonable will be <br />briefly identified, but eliminated <br />from further study. <br /> <br />The Council on Environmental <br />Quality and the Bureau of <br />Reclamation NEPA Handbook <br />gives the following general <br />guidance to help in determining <br />what is "reasonable" for EIS <br />analysis: <br /> <br />Reasonable alternatives should: <br /> <br />· be bounded by the notion of de- <br />sirability <br /> <br />· stress common sense realities <br /> <br />· provide a realistic range of <br />choices to accomplish objectives <br /> <br />. show minor variations as sub-al- <br />ternatives, not separate alterna- <br />tives <br /> <br />. provide a range that reflects sig- <br />nificant differences between al- <br />ternatives <br /> <br />. contain all decision options <br />within the range <br /> <br />. cover a full spectrum - the rea- <br />sonable range depends on each <br />case <br /> <br />. consider actions outside of cur- <br />rent agency capability, jurisdic- <br />tion, or legal authority to <br />implement (if actions are other- <br />wise judged to be reasonable) <br /> <br />. be practical or feasible from <br />technical, economic, and com- <br />mon sense perspectives <br /> <br />. include no action or no change <br /> <br />During a July 1990 workshop on <br />alternatives in Flagstaff, Arizo~ <br />participants, including agency <br />employees and public interest <br />group representatives, were asked <br />to suggest criteria for detennining <br />the specific reasonable alternatives <br />for the Glen Canyon Dam EIS. <br />1bree discussion groups addressed <br />this subject and shared ideas. The <br />result was condensed into the <br />following list. <br /> <br />Reasonable alternatives should: <br /> <br />. meet objectives of the EIS <br /> <br />. be consistent with the scope of <br />the EIS <br /> <br />. be economically feasible <br />. be technically feasible <br />. reflect legal considerations <br /> <br />. have general institutional ac- <br />ceptability <br /> <br />. be timely to implement <br /> <br />. consider existing knowledge of <br />likely problems (common sense) <br /> <br />. have the ability to be monitored <br />and adjusted <br /> <br />. meet various agency mandates <br />(may be in varied degrees) <br /> <br />. be supported by data <br /> <br />. be based on documented condi- <br />tions <br /> <br />. have measurable parameters <br /> <br />. be multi-purpose (or integrated) <br />and not eliminate any major re- <br />sources <br /> <br />. reflect ease or difficulty of im- <br />plementation <br /> <br />. have mitigation included <br /> <br />The EIS team has reviewed the <br />scoping information with the <br />concept of reasonableness in mind. <br />However, there is need for <br />continued discussion on whether <br />the alternatives presented in this <br />newsletter are considered to be <br />reasonable for detailed analysis in <br />the EIS. Reclamation in consultation <br />with the cooperating agencies group <br />will make such a determination after <br />receipt of public input from the <br />current public involvement and <br />review period. If you have views <br />that you desire the cooperating <br />agencies to consider on any of the <br />various "reasonableness" factors <br />listed above or any ideas not listed, <br />please outline them in a letter to the <br />Colorado River Studies Office (see <br />address on back of newsletter). <br /> <br />15 <br />