Federal indirect and cumulative impact requirements of the National Environmental Policy Act (NEPA) process were established in 1978 with the Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act (40 CFR §§ 1500 -1508). The Federal Highway Administration and State Departments of Transportation continue to make progress in incorporating indirect and cumulative impact considerations in NEPA and project decisionmaking, as we enhance our understanding of these issues and the complexities involved.
The purpose of this interim guidance is to focus attention on the existing
NEPA requirements specific to indirect and cumulative impacts. The attached
Questions and Answers Regarding the Consideration of Indirect
and Cumulative Impacts in the NEPA Process is essentially a review of
existing NEPA requirements regarding consideration, analysis, documentation, and
mitigation of direct, indirect, and cumulative impacts. References to indirect
impact and cumulative impact guidance, State DOT procedures, and training opportunities
are provided for your information.
This interim guidance represents an initial step in our overall strategy to
address the indirect and cumulative impacts policy, guidance, and training needs
of the agency. Recognizing the frequent challenges you face regarding the analysis
of indirect and cumulative impacts and the appropriateness of mitigation, we are
planning additional activities, such as the development of supplemental policy
and guidance, the possible revision of the FHWA's 1992 Position Paper, development
of training, and the collection/dissemination of examples and best practices.
With the issuance of this interim guidance, we are inviting FHWA field offices
and interested State DOTs to participate in the effort. We welcome your comments
on the attached Questions and Answers and are interested in knowing what
the States are doing or planning to do regarding guidance and training. We are
also looking for good examples and best practices of indirect impacts and cumulative
impacts analysis at either the planning or project level, including examples of
If you are not already familiar with FHWA's NEPA "community of practice"
website called Re:NEPA (https://collaboration.fhwa.dot.gov/dot/fhwa/ReNepa/default.aspx),
we invite you to take advantage of the information exchange opportunities available
at the site to engage other practitioners regarding the state of the practice
in the indirect and cumulative effects area. For more information concerning this
interim guidance, please contact Lamar Smith, Training, Technology, and Technical
Assistance Team Leader in the Office of Project Development and Environmental
Review at firstname.lastname@example.org
or (202) 366-8994.