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U.S. Department of Transportation
Federal Highway Administration
Sent Via Electronic Mail
Subject: INFORMATION: Interim Guidance: Questions and Answers Regarding Indirect and Cumulative Impact Considerations in the NEPA Process
January 31, 2003
Original Signed by:
From: Frederick Skaer, Director
Office of NEPA Facilitation
Reply to:
Attn. of: HEPE
To: Resource Center Mangers
Division Administrators
Federal Lands Highway Division Engineers

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 documentation.

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 lamar.smith@fhwa.dot.gov or (202) 366-8994.


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