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Steven Blum

Alternatives Analysis. Steven Blum. Alternatives Analysis. When is an Alternatives Analysis required? What is a “reasonable range of alternatives?” What is required in the analysis? Examples of TMDL Alternatives Elements of Alternatives Analysis. The Alternatives Analysis.

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Steven Blum

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  1. Alternatives Analysis Steven Blum

  2. Alternatives Analysis • When is an Alternatives Analysis required? • What is a “reasonable range of alternatives?” • What is required in the analysis? • Examples of TMDL Alternatives • Elements of Alternatives Analysis

  3. The Alternatives Analysis • Evaluate alternatives to The Project that might reduce impacts to the environment • Not to be confused with the requirement under CEQA §21159 for evaluation of alternative means of compliance

  4. Purpose of the Alternatives Analysis • To reduce or avoid environmental impacts • Show the public that we considered a range of solutions to the water quality problem • Foster informed decision-making and public participation

  5. Requirement for Alternatives Analysis • Alternatives analysis not needed for a Neg Dec-level SED • Required for adoption of standards, rules, regulations, or plans (23 CCR §3777) • Required for an EIR-level SED (Guidelines §15126.6)

  6. Requirement for an EIR-level SED • Analysis of alternatives to the proposed activity that may avoid or reduce any significant effects OR • A statement that the agency’s review of the project showed that the project will have no significant or potentially significant effects; therefore no alternatives are proposed. (Guidelines §15252)

  7. Reasonable Range of Alternatives • The range of alternatives required in an EIR is governed by a “rule of reason” – those alternatives necessary to allow a reasoned decision (Guidelines §15126.6(f)) • Alternatives must be feasible • Alternatives should achieve most or all of the project objectives and reduce environmental impacts • General rule: more than 2 and fewer that 6

  8. Limits of the Alternatives Analysis • The environmental document “need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative.” (Guidelines §15126.6(f)(3)) • Even though it’s generally not sensible to have a “no project” alternative for a TMDL, we need to include it in the SED

  9. What Counts as an “Alternative”? • Alternatives should include a range of activities that: • Attain most of the project objectives • Avoid or substantially lessen one or moreof the significant effects of the project Guidelines §15126.6(c)

  10. Considering Alternatives to TMDL Projects • Consider (for example): • Alternative regulatory strategies considered but not pursued (site specific objectives, standards action, etc.) • Alternative implementation approaches that were considered but not further analyzed • Alternatives suggested during scoping and not further analyzed • Provide a brief explanation of why each alternative does not fulfill project objectives

  11. Examples of TMDL Alternatives • Alternative means of achieving the objectives of the TMDLs, suggested by stakeholders or others • Alternative methods for calculating the TMDL or allocating loads • Adjustments to implementation time frame • Standards action (change in WQO or BU)

  12. The No-Project Alternative • The no-project alternative must be considered • “No Project” can be defined as: • No action: Not preparing a TMDL • US EPA prepares a Technical TMDL instead • “The no-project alternative does not achieve any of the project’s objectives, and is inconsistent with legal requirements and the mission of the Water Boards.’” • Discuss and explain choice

  13. Elements of the Alternatives Analysis • Description of each proposed alternative • Describe key aspects of the alternative (differing from the proposed project) • Analysis of environmental effects of each alternative • Indicate ways in which the alternative could feasibly accomplish most project objectives and substantially lessen one or more significant impacts (Guidelines 15126.6(c)) • Provide an analysis of advantages and disadvantages of the alternative

  14. Conclusion of Alternatives Analysis Clearly state why the Water Board has selected the proposed action (particular TMDL allocations, implementation actions, or schedule)

  15. Tips • Develop alternatives based on regulatory considerations, the environmental checklist, and public comment • Present the alternatives analysis after the checklist and explanations of potential impacts • Compare alternatives to potential impacts of the proposed project • Make sure you actually evaluate the impacts of the alternatives (“Rule of Reason,” Guidelines 15126.6(f))

  16. Questions?

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