Wednesday, July 15, 2009

Cumulative Impacts: Preliminary Findings

Research Questions:
Chapter 343 requires that cumulative impacts be addressed in EISs. The review is researching the best way to assess cumulative impacts, their significance, and how to mitigate them.
  1. Does current EIS practice in Hawaii effectively address cumulative impacts?
  2. How can the EIS system be improved to effectively assess cumulative impacts, their significance, and how to mitigate them?
Stakeholder Interview Comments
Overwhelmingly, stakeholders responded that cumulative impacts are not currently adequately addressed through Hawaii’s EIS process. Although in some cases and for some impacts this is done better than in other cases, overall cumulative impact analysis is inconsistent and lacking. This is due to a lack of data, oversight, and clear guidance. Many stated that cumulative impacts would be better addressed on a planning level by more active state and county planning agencies. Attempting to address cumulative impacts on a project-by-project basis without tying this analysis into an overseeing planning framework does not seem to be a good way to realistically assess cumulative impacts.

To address these concerns, the following actions were most commonly suggested:
  1. Link cumulative impact assessment to general plans and planning policy. This will provide a framework to look at these impacts more holistically and to tie the EIS process to zoning, land use, and established state/county/community plans.
  2. Establish baselines or thresholds for quantifiable cumulative impacts so that the EIS process can be better used to assess how projects affect the baseline and whether or not impacts are within or exceed allowable thresholds.
  3. Establish standardized methodology and protocols for measuring, collecting and reporting data, and create state or regional databases to store this data in a central location. (data is needed in order to establish baselines/thresholds.)
Stakeholder Workshop Results
Session 1: Review of Results
The Results Review session of the workshop helped to further clarify the information that came from the interviews. There was general agreement that cumulative impacts are important and should remain part of the EIS process. (Some had suggested that if this could not be adequately addressed, it should not be required). There was also agreement that Hawaii is currently lacking a consistent, universal approach to data collection that is needed to adequately address cumulative impacts.

Session 2: Discussion Group and Report Back
Discussion confirmed that the recommended actions that emerged from the interviews were sound. Government planning should address cumulative impact issues in planning documents that can be referred to when preparing EISs. Agencies should create baseline data and there should be standard methodology for handling data in the EIS process. Proponents should address how their projects affect the baselines. Discussion confirmed the need for stronger, more proactive higher-level planning that can be linked to the EIS process, and a need for this planning effort to include establishing baselines or thresholds for cumulative impacts (at least for impacts that are quantifiable). Some questioned whether the responsibility for cumulative impact analysis should rest with individual project proponents, or if it would be more suitable for an accepting or overseeing agency to address this.

Some other interesting points that arose from this discussion include the following: (1) Some impacts are more qualitative than quantitative and thus more difficult to measure, or to establish baselines/thresholds for. There should be further research into what these impacts are and how to best address them. (2) Guidance is important to help define the boundaries of how cumulative impacts are addressed in the EIS. Without clear limits, this requirement can be taken too far and become unreasonable. (3) It might be more appropriate for the accepting agency for cumulative impacts to be the county (i.e. not an agency like DOH simply because wastewater was the trigger for the project) (4) Having unbiased documents is necessary to ensure that impacts are not downplayed or unrealistically mitigated. A 3rd party preparer system might better achieve this.

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