WHEN ARE SECONDARY AND CUMULATIVE IMPACT ANALYSES APPROPRIATE?
Under the CEQ regulations, the FHWA must consider the possibility of secondary and cumulative impacts on all agency actions. However, we will obviously concentrate on construction actions which have a potential to produce indirect environmental consequences. Secondary and cumulative impact analyses should be based on the possibility of indirect effects combined with various site specific conditions which will shape the scope and intensity of the studies necessary to provide adequate information to the project decisionmakers. An important consideration is an estimate of the potential for development in the area of a proposed project within a reasonable period of time. The estimate should recognize the potential both with and without the project,, In areas experiencing little growth over time, an individual highway project will likely have a negligible contribution to a cumulative impact because of the absence of other activities occurring in the vicinity. Conversely in areas of moderate