Reviewing An Environmental Assessment For Its Treatment of Cultural Resources

Textbook: Any Environmental Assessment (EA)

Preparation: If you, the student, are personally or professionally interested in a particular EA, you can use that document. If not, your instructor may assign you an EA to review or you may select one yourself from any available to you. If you are not reviewing the EA based on your own interests, you should assume any one of the following roles:

  1. Individual concerned with historic buildings, structures, and districts
  2. Representative of indigenous group concerned with impacts on culture, lifeways, and spiritual places
  3. Archeologist
  4. Individual concerned with cultural landscapes
  5. Community representative concerned with impacts on community ambience and lifestyle

The role selected should relate somehow to the environment potentially affected by the action analyzed in the EA. For example, if you want to play the role of someone concerned with historic buildings, you should not select an EA to review that concerns a timber sale where there are not any buildings.

Assignment: Review and critique the EA both for its general treatment of cultural resources and for how it addresses (or fails to address) your own particular real or assumed/assigned interests. Use the NEPA pages in doing review and preparing the critique.

Be sure to consider the following:

  • Is the EA organized into approximately the following elements? If so, what are the pros and cons of this sort of organization?
  1. Cover sheet
  2. Summary
  3. Table of contents
  4. Purpose of and need for action
  5. Alternatives including proposed action
  6. Affected environment
  7. Environmental consequences
  8. List of preparers
  9. List of agencies, organizations, and persons to whom copies of the EA were sent
  10. Index
  11. Appendices (if any)
  • Does the EA present alternative ways of achieving the purpose of the project? If not, is there a good reason it does not?
  • Does the EA describe the contexts in which impacts may occur? If so, what are they?
  • Does the EA discuss the intensity of likely impacts as outlined in 40 CFR 1508.27?
  • Does the EA describe historic properties subject to possible impact?
  • Does the EA describe cultural resources other than historic properties? If so, what are they?
  • Does the EA discuss what effects are likely on cultural resources?
  • Does the EA propose ways of avoiding, reducing, or mitigating adverse effects on cultural resources? What are they? Do you think they are adequate?
  • Is it likely that cultural resource legal authorities, in addition to NEPA, are relevant to the project and its effects? If so, how does the EA address them?
  • Is the EA responsive to culture-related environmental justice concerns?
  • Does the EA reflect consultation with stakeholders having cultural resource concerns? Has the consultation been adequate?
  • Does the EA lead to a clear and understandable conclusion as to whether the project is likely to have significant impacts on the quality of the human environment? Do you agree with the conclusion from a cultural standpoint? Why or why not?

Draft a letter to the agency responsible for the EA, providing comments and telling the agency what you think of the EA and what you think the agency should do. If you have an instructor, turn the letter in to the instructor for review and critique. In self-instruction, critique the letter yourself, referring to the cheat sheet.