How should EPA review cumulative impacts analyses in NEPA documents?
A. The assessment of cumulative impacts is not substantially different from the assessment of direct or indirect impacts. The same type of consideration is made to determine the environmental consequences of the alternatives for direct, indirect, or cumulative impacts. One possible difference is that cumulative impact assessment entails a more extensive and broader review of possible effects. Reviewers should recognize that while no “cookbook” approach to cumulative impacts analysis exists, a general approach is described in the CEQ handbook. As with the review of direct or indirect impacts, EPA review of cumulative impacts analysis is most effective if done early in the process, especially in the scoping phase. Federal agencies have the responsibility of determining how and the extent to which cumulative impacts are assessed in NEPA documents and documenting that effort. In reviewing the analysis, the EPA reviewer should determine if the information presented is commensurate with the
