Abstract
The Council on Environmental Quality (CEQ) regulations for implementing the National Environmental Policy Act (NEPA) define cumulative effects as, “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions.” (40 CFR §1508.7) Accordingly, NEPA requires agencies to consider not only the incremental direct and indirect effects of a particular action on environmental resources, but also the cumulative effects of the action that occur in combination with other actions. The purpose of the cumulative effects analysis is to ensure that the decision maker fully considers the consequences of the proposed action (CEQ 1997).
CEQ’s guidance for evaluating cumulative effects as part of NEPA analyses specifies the need to include all relevant past, present, and reasonably foreseeable future actions and to focus on truly meaningful effects. Agencies are charged with developing action- or activity-specific cumulative impacts scenarios in accordance with this general guidance. Considering expected growth in renewable energy renewal offshore North Carolina to northern Florida, the purpose of this document is to establish a common cumulative impacts scenario framework for use in NEPA analyses for offshore wind activities on the South Atlantic Outer Continental Shelf (OCS). This will enable efficient and effective identification of relevant actions for the cumulative effects analyses, and the development of consistent, succinct NEPA documents that demonstrate sound logic for cumulative effects findings.
This document provides the following guidance to establish cumulative impact scenarios for future renewable energy projects on the South Atlantic OCS:
- Identifies the important cause-and-effect relationships between renewable energy projects and potentially affected resources. BOEM refers to these relationships in terms of the Impact Producing Factors (IPFs) generated by these activities that directly or indirectly affect physical, biological, economic, or cultural resources. Based on these IPFs, this document identifies the relevant affected resources that should be considered in the cumulative impacts analysis.
- Identifies the types of actions and activities to include in the cumulative impacts scenario. This document identifies multiple types of actions and activities (including federal, non-federal and private actions) that may affect the same physical, biological, economic, or cultural resources as the renewable energy actions that should therefore be considered in terms of the collective effects. These “cumulative actions and activities” may generate the same IPFs as renewable energy or affect the same resources in other ways (i.e., via different IPFs).
- Identifies past, present, and reasonably foreseeable actions and activities in the South Atlantic OCS to consider in future NEPA cumulative impact scenarios. Chapter 3 of this document provides activity-specific overviews of activity levels and locations, presenting information in tables and maps where possible. This information may be used as a starting point for cumulative effects analyses for future renewable energy projects. This information reflects the state of knowledge as of March 2020; future analyses will therefore require some additional research to ensure the cumulative impacts scenario is current.
- Provides guidance on and information sources for identifying relevant past, present, and reasonably foreseeable actions for each action/activity. Cumulative impact scenarios for renewable energy projects will be location-specific and will therefore require some additional research regarding the specific actions and activities to be included (e.g., amount of vessel traffic or extent of dredging and presence of disposal sites). Chapter 2 of this document defines resource-specific spatial boundaries that identify the area over which relevant actions and ii activities may affect a given resource. The action and activity-specific sections of Chapter 3 then direct analysts to the best available information sources to identify and quantify the relevant actions and activities.