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Tennessee Environmental Procedures Manual

Chapter 5: Impact Analysis

5.4 Refine Alternatives, as Warranted by Impact Findings

The impact studies and public involvement activities may identify major issues that must or should be addressed before an alternative is presented in the draft NEPA document.
Such issues could include:

  • Need to evaluate alternatives to avoid Section 4(f) use and determine if they are prudent or feasible;
  • Existence of a historic family cemetery in an area where the alignment can be slightly shifted to avoid impacts;
  • Archaeological sites (e.g., Can the alignment be shifted to avoid a National Register-eligible site or sites?);
  • Extensive wetland impacts (e.g., Are there alternatives that would either avoid or minimize impacts?);
  • Environmental justice (e.g., What can be done to avoid disproportionately high and adverse impacts on a minority population?); and
  • How can access be provided from the proposed controlled access road to a new industrial park or an existing large industrial employer?

These issues should be displayed on an updated "environmental constraints" map by the Environmental Division planner or by a consultant. The planner should ask for assistance from the Natural Resources Office or the Social and Cultural Resources Office, as needed. At a minimum, the planner should prepare a memorandum for transmittal to the project concept designer or the Project Manager, calling these issues to his/her attention.

The Project Manager, planner and project designer, and as applicable, the staff of Natural Resources Office or the Social and Cultural Resources Office, or the consultant, should then meet to discuss how these issues impact the project alignment, the technical studies that may have already begun or will soon begin, and the project schedule. Addressing issues at this early project stage through minor alignment shifts or other means may save time and avoid problems at later project stages.

It is important to note that any shifts in project alignment, whether minor or major, may require additional technical field studies and analyses or study updates to be completed in the "added" project impact area. Examples include the need for archaeological studies in areas within the new project area that were not previously surveyed or updating the numbers of displacements where additional right-of-way would be required.

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