Cumulative Effects Assessment for EIS
Proposed Gogebic Mine
Briefing by WDNR and Barr Personnel
NEPA Guidance, 40 CFR parts 1500-1508, for cumulative effects was briefly discussed by WDNR and Barr personnel.
Tribes had some questions on the reach of the cumulative effects analysis. For example, would ports for shipping ore be included in the cumulative effects analysis.
Briefing by the Corps
NEPA regulations overall are not prescriptive.
There is no clear guidance on how to manage a cumulative effects analysis, and the analysis will not be the same for any two projects.
I asked that the parties take a look at the following:
1997 CEQ Guidance – Considering Cumulative Effects Under NEPA
Corps Procedures for Implementing NEPA – 33 CFR Part 230
The document provides Corps guidance but mostly cross-references 40 CFR 1500-1508. There is nothing specific to cumulative effects but there is some information in for integration with state and local procedures.
Corps headquarters is currently developing guidance for a cumulative performing a cumulative effects analysis. However, at this time that guidance is neither here nor there and it may take several years for the Corps to develop the guidance.
Emphasis should be placed on water an air modeling to evaluate the extent of impacts from the project and evaluating boundaries for meeting air and water quality standards. Then evaluate existing and reasonably foreseeable projects in the area and consider whether there is a cumulative impact. The cumulative effects analysis is likely to be heavily dependent on modeling.
SDEIS for the PolyMet project will be publicly available for download from the Minnesota Department of Natural Resources website by COB December 6. Might want to watch for comments on the document and then adjust where you feel that it may be necessary for the Gogebic project.
The following recommendations were provided
For the cumulative effects analysis, you don’t want to be overly prescriptive. That would dilute the analysis. Focus on cumulative effects from nearby activities that are meaningful and actually contribute to the cumulative effect to the proposed action, whether they are direct or indirect.
Threatened and endangered species - The EPA is starting to take a hard look at impacts to wildlife corridors and compensation for wildlife conservation areas should be considered.
Cultural – Should be evaluating cultural resources impacts now. It may take some time to work through t