Part 2 - Identification of Potential Project Impacts (FEAF)
Full Environmental Assessment Form (FEAF) Workbook
Part 2 is to be completed by the lead agency.
Part 2 is designed to help the lead agency inventory all potential resources that could be affected by a proposed project or action. We recognize that the lead agency's reviewer(s) will not necessarily be environmental professionals. So, the questions are designed to walk a reviewer through the assessment process by providing a series of questions that can be answered using the information found in Part 1. To further assist the lead agency in completing Part 2, the form identifies the most relevant questions in Part 1 that will provide the information needed to answer the Part 2 question. When Part 2 is completed, the lead agency will have identified the relevant environmental areas that may be impacted by the proposed activity.
The purpose of Part 2 is to use the information from Part 1 to identify potential adverse impacts that need further consideration by the reviewing agency. The questions included in Part 2 are designed to help the reviewing agency identify what, if any, impacts may occur as a result of the project. Part 2 is further used to decide whether those impacts will have no impact or a small impact, or a moderate to large impact. Nothing in this workbook, particularly the guidance offered in Part 2 and 3, is found in regulation. While the EAF's need to be completed according to Part 617 regulations, interpretation on the size or significance of an impact is at the discretion of the reviewing agency.
Completing Part 2 will help identify any topics that need to be discussed further in Part 3. Taken together, Part 2 and Part 3 will help the reviewing agency determine if a negative or positive declaration is appropriate. If a positive declaration is made, parts 2 and 3 will help the reviewing agency develop a list, or 'scope' of environmental topics that will need to be addressed further in an environmental impact statement.
Note that nothing in this workbook, particularly the guidance offered in Part 2 and 3 is found in regulation. While the EAF's need to be completed according to the Part 617 regulations, interpretation on the size or significance of an impact is at the discretion of the reviewing agency.
Importance of Scale and Context
When you have determined that a potential impact may occur, you will also need to decide if that impact will be small or moderate to large. This decision should be based on the magnitude of the potential impact. Magnitude is not just the physical size of the project in feet or acres. Magnitude also considers the scale and context of a proposed project, and severity of that project's impact.
Scale refers to both the size and the intensity of the project. The scale of a project can be measured several ways. It includes the overall size of the project site, the number of buildings or structures proposed, the size of the parking lot, or the height and other dimensions of buildings. It also refers to features that measure the intensity of the project such as the amount of traffic that will be generated, or the amount of land to be cleared and graded in relation to the entire parcel size.
Context refers to the conditions on the project site and its relation to adjacent parcels, the neighborhood, and the community as a whole. Similar projects in different settings may have very different environmental impacts. For example: construction of a commercial building that is 10,000 square feet in size in a community that is already developed, has public water, sewer and storm drains, and is on a lot that has already been cleared will have very different impacts than the same sized and scaled project built in a rural, undeveloped community, with no public infrastructure, and little other development nearby. In this example, the scale is similar but the context is very different.
An impact is measured in part, by its magnitude. The magnitude of an impact depends on the overall size, setting, and severity of the impact. A project that will disturb a few hundred square feet of land might be considered small in area, but if it destroys 100% of a rare species habitat, the severity of that impact would be considered large. Likewise, the construction of a warehouse in an established industrial district might be large in area, but the severity of the impact might be considered quite small, or even non-existent.
Part 2 asks reviewing agencies to identify if an impact will occur, and if so, what the size of that impact will be. The magnitude of an impact should be determined based, as much as possible, on the facts provided in Part 1, and on the scale and context of the project. A proposed action could have no impact on the environment, or an impact could be small, or moderate to large. In Part 2 of the FEAF, moderate and large impacts are considered together.
- No Impact: No impact will occur if the proposed action is consistent with the community's adopted plan and zoning, does not cause a change in the intensity of land use in the area, does not change the quality of the existing community or its character, does not change or impact any environmental resource or infrastructure, or create a hazard to human health as identified in Part 1.
- Small Impact These are impacts that are minor in magnitude and that have small or limited effects on environmental resources. Small impacts may also occur when an impact is limited to a small area. Small impacts are usually isolated, of minimal size, intermittent or short in duration (days to weeks), and do not affect rare or unusual species, habitats, or other resources. Small impacts include those that would generally be considered negligible and minor. These are often impacts from activities or resources that are not regulated or protected by any local, state or national agency.
- Moderate Impact: These are impacts that are moderate in magnitude and that have more impact on environmental resources. Moderate impacts can also occur when the impact affects a larger part of the parcel or even extending to a small area just beyond the parcel. Moderate environmental impacts may be either isolated (only in one location), or of regional concern (in a larger area). They generally are longer lasting (duration measured in weeks or several months), are often reversible and can be more readily addressed through mitigation measures or project changes. The resources affected often have broader local or regional concern and often are activities or resources that are regulated or protected by some local, state, or national agency.
- Large Impact: These are impacts that are severe in magnitude or cover larger areas in the neighborhood or community. The environmental impacts anticipated could be irreversible, challenging to mitigate, of wide regional scale, or of long duration. A large impact may also be unlikely to occur, but if it does, would be very damaging to the environment. The resources affected often have broader local or regional concern and often are activities or resources that are regulated or protected by some local, state, or national agency.
These descriptions of no or small impact, and moderate and large impacts are not always clearly defined, however. An impact to a very small area that is home to a rare species would generally be considered a large impact because it could severely impact that rare species. And a project that affects many acres may not affect any resources. When evaluating whether a proposed action has an impact, and if so, how large it is, the reviewing agency must consider the size, scale, magnitude, and resources in and around the location together.
Instructions for Completing Part 2
It is the reviewing agency's responsibility to answer all Part 2 questions, 1 through 18.
If the reviewing agency is a state agency (link leaves DEC website) and the action is in any Coastal Area, the reviewing agency must complete the Coastal Assessment Form before proceeding with this assessment.
See the Coastal Assessment page for further instructions.
You should use information submitted by the applicant or project sponsor in Part 1 to answer these questions. That includes additional information that may be submitted by the applicant. The reviewing agency can request clarification or expansion of information submitted in Part 1 if it is needed to answer the questions in Part 2. New information that is requested could come from currently existing or readily available sources, or site specific information collected as part of a survey, inventory, or other data collection. It is not intended that exhaustive new studies on all resources be required to complete Part 2. If, after your analysis, the reviewing agency finds that there is potential for at least one or more moderate to large impacts, Part 3 will be used to examine the impacts in more detail and a determination of the significance of those impacts will be made.
You may find it helpful to follow these steps to complete the Part 2 questions:
- Review answers to Part 1, questions A through G. This will help you become familiar with the project area. If you feel there is missing or incorrect information, you can request clarification or additional information from the project sponsor or applicant.
- Use the sub-questions to help you decide the size of a potential impact. Keep in mind that these sub-questions are meant as examples of impacts. Reviewing agencies should consider all the impacts of the specific project even if these sub-questions are not relevant. If other impacts are identified, use the 'other impacts' sub-question for those that are not otherwise captured in the examples provided on the form.
- Be sure to consider all components and phases of the proposed activity in the Part 2 evaluation. The responsibility of the reviewing agency is to evaluate potential impacts from the entire project, even if some components are proposed to be years apart.
- Consider long-term, cumulative, and direct impacts. Some actions may have short-term impacts (for a few days, weeks or months) which improve quickly and thus may be of minor or negligible importance in a long time frame. Conversely, other actions may last for many months or be permanent.
- Cumulative impacts are those reasonably foreseeable impacts that result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other action. Reasonably foreseeable is when something is sufficiently likely to occur within the projected build year(s).
- Reviewing agencies should consider impacts, that when added to other existing or future projects will cumulate into larger ones. For example, if a project was to construct a new coal fired electric generating unit, but it is adjacent to an existing electric generating plant, the project would be constructed with the allowance for expansion, and in the same industrial district, there is also an operating ethanol plant, there is a potential for cumulative impacts above and beyond those that may occur as the result of the proposed project alone. In that example, the cumulative impacts on air quality, traffic, and water may be significant.
- Impacts can also be either direct or indirect. Direct impacts are those that are caused by the action and occur at the same time and place. Examples of direct impacts would be traffic noise, alteration of visual character, changes in traffic patterns, or filling a wetland.
- Indirect impacts are those that may be caused by a project, but occur at a different time or place. Indirect impacts may include growth-inducing effects, cumulative impacts, and other effects related to changes in the pattern of land use, population density or growth rate and related effects on air and water and other natural systems.
- Many of the sub-questions contain thresholds for impacts. DEC established these thresholds in consultation with experts in various fields. For example, 1 (d) asks if the proposed action may involve the excavation and removal of more than 1,000 tons of natural material. The 1,000 tons establishes a threshold. These thresholds are intended to scale potential impacts or to separate out actions with relatively minor impacts from ones that may have larger impacts. The thresholds are not absolute, but if an impact is below a particular threshold it helps the reviewing agency to answer that a particular impact is more likely to be small. It will be important to evaluate impacts in the context of the community in Part 3, but this is to be done only where the reviewing agency has determined that an impact may be moderate to large. If the numeric threshold is exceeded in a question, the reviewing agency should check "moderate to large impact may occur". If a potential impact could occur but does not exceed the threshold, check "no, or small impact may occur." Please be aware that there could be deviations from these thresholds and impact assignments. If so, explain in Part 2. For example, an action below a threshold will result in a potentially large impact. Usually context will play a role in such decisions.
- Using the workbook web pages as a guide, work through answering questions 1 through 18. Each question page includes references to pertinent Part 1 questions, and a process for deciding if there is any impact, and if so, what the magnitude of that impact might be.
- Fill in the Part 2 table on the FEAF.
- Check 'No or small impact may occur' if you determine that there will be no impact or only a small impact to that resource.
- Check 'Moderate to large impact may occur' if you determine there may be a moderate to large impact to that resource
Each of the Part 2 questions explores a different environmental topic. These topics, in general are:
Question 1: Impact on Land
Question 2: Impact on Geological Features
Question 3: Impacts on Surface Water
Question 4: Impact on Groundwater
Question 5: Impact on Flooding
Question 6: Impacts on Air
Question 7: Impact on Plants and Animals
Question 8: Impact on Agricultural Resources
Question 9: Impact Aesthetic Resources
Question 10: Impact on Historic and Archeological Resources
Question 11: Impact on Open Space and Recreation
Question 12: Impact on Critical Environmental Areas
Question 13: Impact on Transportation
Question 14: Impact on Energy
Question 15: Impact on Noise, Odor, and Light
Question 16: Impact on Human Health
Question 17: Consistency with Community Plans
Question 18: Consistency with Community Character
Moving on to Part 3
When the Part 2 table is complete, proceed to Part 3.
- If you checked "No or small impact may occur" for all eighteen questions in Part 2, then you are only required to check the "this project will result in no significant adverse impacts on the environment" line from Part 3, fill out the reviewing agency information, date, and sign the form.
- If you checked "Moderate to large impact may occur" for any question in Part 2, then each of these will need additional evaluation in Part 3. Part 3 will help the reviewing agency decide if the impacts identified are significant, whether impacts will be avoided or substantially mitigated, and whether or not to require an environmental impact statement.