Final Paper Mock EIS

Marriott, B. (1997). Environmental impact assessment: A practical guide. New York, NY: McGraw-Hill.

16.1 Describing Existing Resources

The level of detail on geology and soils required to determine the po- tential fOT impact, and thus included in Section III of the DEIS or within the EA, will greatly depend on the type of project alternatives being proposed. Projects requiring excavation or tunneling or causing changes in drainage patterns may dictate more detailed studies than those with no substantial surface disturbance.

16.1.1 Geologic features

As a basis for impact assessment, the analyst should obtain an under- standing of the basic physiography and topography of the site or area and the underlying geology. Local planning documents and discus- sions with local agencies will normally provide geologic information.

The U.S. Geological Survey (USGS) also is an excellent source of in- formation on geology, geologic hazards, groundwater quality, and sur- face water flow characteristics. The USGS is the principal source of scientific and technical expertise in the earth sciences within the fed- eral government and has been providing data and reports for more than 100 years (U.S. Department of Interior, USGS 1995£).

Information and mapping will indicate important characteristics of geologic formations, such as stability for construction, permeability and porosity, groundwater aquifers, seismicity and faults, sinkholes, springs, natural gas or oil wells, surface and deep mines, mineral re- sources, and volcanic activity. Engineering limitations and constraints may include difficulty of excavation, cut slope stability, and foundation stability. In earthquake-prone areas, regional risk assessment maps are available from the USGS. Based on collected ground-motion data and other geologic information, the hazard maps provide estimates of the probability of significant ground movement and the potential areas of landslides, mud flows, and liquefaction. Liquefaction is the temporary change of a saturated soil or fill to a liquid, which produces a corresponding loss of support strength for structures.

16.1.2 Seismicity

If applicable to the study area, existing information on faulting and seismicity should be included in the environmental document. Often information on faults will be available on a regional basis and on a very localized basis through local universities or independent experts. Previous environmental studies for other projects in the area are a valuable source of information. Normally, major faults will be readily identified, but minor faults may not be identified or may be identified only as "potential.

Detailed studies on existing faulting and seismicity characteristics would be conducted by qualified geologists or geotechnical engineers. In some cases, it may be necessary to excavate test pits or trenches to investigate fault potential. The trenches would permit determination of the age of the subsurface material and evidence of surface rupture through examination of whether underlying strata are continuous or discontinuous. Discontinuous strata could indicate fault ruptures.

Information available from a seismicity study will normally include the maximum credible earthquake (MCE) and the maximum probable earthquake (MPE) magnitudes. The MCE is the largest possible earth- quake considering the known tectonic framework of an individual fault, and the MPE is the largest earthquake likely to occur with a 100-year return period. Associated with these estimated maximum earthquake magnitudes, the peak horizontal ground acceleration is calculated. The duration of strong ground shaking for each fault also may be estimated.

The seismicity information in the environmental document should in- clude history of earthquakes in the project area or region, their magni- tudes, and the locations of epicenters. Characteristics of the earthquake activity, as related to study area faults, should be described, if known.

16.1.3 Mineral resources

The description of mineral resources should include a summary of po- tential mineral ores, natural gas, oil, geothermal resources, and sand and gravel. Mineral ownership, existing and proposed resource recov- ery activities, and the potential for resource development should be de- scribed, if relevant to the characteristics of the proposed project or action. The potential for undiscovered mineral resources has already been assessed for some geographic areas, and it depends mostly on the underlying geology. For example, an area's potential for oil and gas pools in a favorable spatial relationship is rated high if three geologic necessities exist: (1) a geologic trap, an impermeable lithologic barrier, to prevent the oil and gas from escaping to the surface; (2) suitable reservoir rock, a unit with sufficient porosity and permeability to hold a quantity of oil and gas and transmit it when penetrated by drilling; and (3) mature source rock, usually a carbon-rich shale or limestone, which could have generated hydrocarbons during burial, compaction, and heating. Most of the lands within national forests or under the ju- risdiction of the Bureau of Land Management have been mapped for low, moderate, or high potential for each ofvarious mineral resources.

Mter the potential for resource is known, nongeologic factors influ- ence whether the resources are actually feasible to develop. These economic-setting factors include the market value of petroleum and the geography of the area. Geography is important in calculating the cost of recovery, such as rugged terrain, distance from support facili- ties, and distance from markets, which may make the expected re- turns from drilling insufficient to cover extra expenses incurred.

Both the potential presence of mineral resources and economic fea- sibility enter into the determination of potential for resource develop- ment. The potential for development should be included within the environmental document if it is predetermined, mapped, and relevant to the type of proposed project or action being considered.

16.1.4 Soil surveys

Information and mapping on soils are available in soil surveys from the Natural Resources Conservation Service (NRCS), formerly the Soil Conservation Service (SCS). For each soil map unit, the soil sur- vey provides an abundant amount of information related to other areas of potential impact. Depth to groundwater, erodibility, and drainage characteristics will be important to assess the potential im- pact on water resources. Depth to bedrock, permeability, available moisture capacity, and suitability or limitations for construction use may affect engineering studies and whether local soils would need to be removed and/or replaced prior to construction. Limitations identi- fied for each soil series would include such information as high frost heave potential, possible sinkholes, flooding potential, slow perme- ability, or seasonal high-water table.

Infonnation for each soil type includes the types of soils, such as silt loam, clay, and alluvium and the percentage of slope of the land within the mapping unit. The soils survey also provides interpretations for different uses, such as cropland, forest land, rangeland, homesites, recreation, wildlife habitat, and septic tank filter fields. The survey will identify prime farmland soils, soil of statewide importance, and hydric soils. Hydric soils are soils that are saturated, flooded, or pond- ed long enough during the growing season to develop anaerobic (no- oxygen) conditions in the upper part. Infonnation on the presence of hydric soils is necessary for the identification of wetlands and is dis- cussed further in Chap. 20.

16.1.5 Contents of the environmental document

Because of the abundant information on geologic resources and soils that will be available for review, it is extremely important that the environmental analyst remain focused on relevant issues and con- cerns. The characteristics of the proposed project or action and the re- sults of agency and public scoping should direct the review of available information to that which may assist in impact evaluation. Special geologic constraints, hazards, mineral resources, and soil characteristics within the actual area of potential impact should be summarized in the environmental document. The presence of hydric or prime farmland soils should be indicated and mapped, if signifi- cant. The goal is to identify any possible serious constraints or con- flicts in compatibility of the proposed project or action with existing geologic and soil resources characteristics.

16.2 Geologic Impacts

The evaluation of geologic impacts and geology-related impacts will be specific to the type of project proposed for implementation. Often impacts are avoided through incorporation of specific design criteria within permits or contractors' specifications. Mineral resource recov- ery has direct geologic impacts. Geology-related impacts can occur, particularly to groundwater and surface water resources.

16.2.1 Geologic hazards

In the assessment of possible geology-related impacts, it is important to first attempt to avoid geologic hazards or existing resources, such as sinkholes, caves, gas wells, surface mines, or gravel quarries. Emphasis again is placed on the continuing process of refining alternatives throughout the environmental impact assessment process. Alternatives should minimize impact related to geologic hazard areas as much as possible through shifts in site locations or design characteristics.

16.2.2 Land-use compatibility

In many situations, the evaluation of geology and soi1s·related im- pacts is basically an evaluation of land-use compatibility. The charac- teristics of the proposed project or action should be overlaid upon the critical relevant geologic and soils data to determine the compatibility of the proposed use with the existing features of the geology and soils.

For many types of projects, this evaluation of land-use compatibility has already been done and is reflected in various building codes, legis- lation, regulations, and permits. For example, a certain type of landfill must not be built within 200 ft of land that has been ruptured by Holocene faults (active within the past 10,000 years). Some design cri- teria for buildings, landfills, dams, and highway structures are based on assumptions related to seismic activity. The structures must be de- signed to withstand a certain earthquake magnitude and horizontal

ground acceleration without damage to foundations or structures that control pollution and without risk to human life or property.

16.2.3 Mineral resources

Potential impacts on mineral resources and resource development will be most critical with environmental studies when the proposed project or action is a land-use or management plan, such as those for national forests or land under the jurisdiction of the Bureau of Land Management. The analyst again should be aware that various federal and state agencies have been established with specific directives on the resources under their jurisdictions. See the discussion in Chap. 5 on the conflicts that can sometimes arise because of differing mandates, in that example between the Environmental Protection Agency's re- sponsibility to protect the nation's air quality and the Department of Transportation's responsibility to provide the nation with safe and effi- cient transportation.

As an example related to mineral exploration, and development on federally owned lands, it is frequently unknown by the general public that the same act (Organic Act of 1897) that created the National Forest System also opened the national forests to mineral development. Forest Service mineral management policy was first set in 1907. Under the caption "To the Public" Gifford Pinchot, first chief of the Forest Service, gave the following directive:

The timber, water, pasture, minerals and other resources of the National Forests are for the use of the people. They may be obtained under rea- sonable conditions without delay. Legitimate improvements and busi- ness enterprises are encouraged.

Numerous directives and laws since that time have reinforced the general mineral resource management policy of the systematic discov- ery and characterization of mineral and energy resources so that the most important deposits can be developed and utilized to best meet the needs of society. Because the Forest Service does not discover or develop energy or hardrock mineral resources, the achievement of the policy is defined by the amount of access provided to industry so it may discover and develop the nation's mineral resources. The guideline against which mineral resource management is measured is that at least 75 percent of the federal mineral estate is available for reasonable and prudent ener- gy or mineral exploration (U.S. Department of Agriculture, Forest Service 1992a). The area involved, however, is small; less than 1 percent ofnational forest land has ever been disturbed by mineral development.

Protection from adverse impact to the environment by mineral re- source development is ensured through requirements for environmen- tal impact assessment of proposed activities and for reclamation of lands disturbed by mineral and energy activities for other productive uses. Mineral exploration and development is a temporary and widely scattered land use. Mineral commodities are open to development only under leases, permits, or licenses issued by the Bureau of Land Management, which has the responsibility for leasing all onshore fed- eral minerals. Environmental analysis is required for each stage of mineral development activities.

The direct impact of mineral resource development on mineral re- sources is depletion of the resource and associated benefits to the na- tion's energy and minerals supply and security. Indirect effects may be the creation ofjobs and economic benefits at the local, state, and feder- allevels. Direct effects on soils may include disturbance within highly erodible soils (refer to discussion of soil erosion later in this chapter).

Mineral resource development can produce direct and indirect, sec- ondary effects on other resources and, in this sense, is evaluated in an Environmental AssessmentlFinding of No Significant Impact or Draft and Final Environmental Impact Statements, the same as any other proposed project or action. Impacts are possible to air quality, water, wetlands, recreation, visual quality, cultural resources, vegetation and wildlife, and socioeconomics.

16.2.4 Geology-related effects

Other types of impacts associated with geologic conditions include these:

• Removal and disposal of unsuitable material

• Leaching of pollutants into groundwater systems

• Interception of the water table through excavation and resultant re- quired pumping (dewatering) during construction

• Exposure of acid-producing geologic formations to rainwater

Geologic considerations are directly related to the quantity and quality of groundwater resources. These potential groundwater and surface water impacts are discussed in greater detail in Chap. 18.

16.2.5 Interdisciplinary approach

If the proposed action is a construction project, such as a building, mall, highway, bridge, or harbor improvement, engineers will be an important part of the multidisciplinary team working on the develop- ment of project alternatives. In these cases, engineering investigations of geotechnical conditions will be conducted. These investigations will normally focus on the engineering suitability of geology and soils in the area, as opposed to natural qualities such as groundwater leaching or exposure of acid-producing formations.

There will, however, be overlap in many areas of information valu- able to both engineers and environmental impact analysts. The im- portance of continued team interaction and sharing of information cannot be overemphasized. Often those in environmental disciplines can make engineers aware of potential problems early in the design process. Moreover, engineers will be able to directly answer questions required for the environmental team members to fully understand ex- actly what will occur during construction so that the degree of poten- tial impact can be properly evaluated.

Detailed subsurface engineering studies are undertaken after the environmental impact assessment process, during final design, and before construction of the selected alternative, to ensure no major im- pact related to foundation or stability conditions.

16.3 Erosion

Although many people in the United States no longer think about it in any detail, the nation's soil is an extremely important natural re- source for food production and public welfare. As early as 1935, the Soil Conservation and Domestic Allotment Act recognized that "the wastage of soil and moisture resources on farm, grazing, and forest lands of the Nation, resulting from soil erosion, is a menace to the national welfare..." and established the Soil Conservation Service (now the Natural Resources Conservation Service) with the purpose of providing permanently for the control and prevention of soil ero- sion.

As with hydric and prime farmland soils, the Natural Resources Conservation Service has identified highly erodible soils. The agency prepares, and makes available to the public, lists of highly erodible soil map units. The determination has been made through application of the highly erodible lands criteria (7 CFR Part 12). The criteria use two basic formulas for determining the erosion rate: that due to rain- fall and that due to wind. These erosion rates are then divided by a predetermined soil loss tolerance value.

The soil erosion rate due to rainfall is calculated by using the uni- versal soil loss equation (USLE). The USLE is a multiplication of three factors: rainfall and runoff R, the degree to which the soil re- sists water erosion K, and a factor (LS) describing the effects of slope length (L) and steepness (S). The resulting number represents the potential average annual rate of sheet and rill erosion due to rainfall.

The potential average annual rate of wind erosion is estimated by using the wind erosion equation (WEQ), which multiplies two factors: the climatic characterization of wind speed and surface soil moisture C by the degree to which soil resists wind erosion 1.

Values for all the factors used in the soil loss equations are calculat- ed, or are already contained in the soil survey information by soil map unit, using methodologies explained in the U.S. Department of Agriculture handbooks or Natural Resources Conservation Service field office technical guides and references.

The criterion for highly erodible lands, then, is the result of the rainfall or wind erosion rate calculation divided by a factor T repre- senting a predetermined soil loss tolerance. The T value represents the maximum annual rate of soil erosion that could occur without causing a decline in long-term productivity. The designation of highly erodible lands, therefore, is not based solely on actual erosion, but on the relationship of erosion rates to the maintenance of desired pro- ductivity, or use, of the land.

The evaluation of potential soil erosion impacts will focus on the amount of ground to be cleared at anyone time, the slope of ground, erodibility of exposed soils, and rainfall potential. The universal soil loss equation can be used to predict the amount of soil potentially lost to erosion, if the project warrants a detailed assessment. Soil erosion can produce a direct impact on aquatic life in surface waters through sedimentation, as discussed in the chapter on water resources.

Fortunately, most environmental analyses of potential erosion ef- fects for small, site-specific projects will be able to conclude that, with implementation of proper mitigation measures, the remaining impact will be negligible. The potential for impact, however, is important to establish the required mitigation. State-of-the-art erosion and sedi- mentation control techniques are available to all contractors and are usually contained in contract specifications in detail, including timing and staging of placement of erosion control measures related to con- struction activities. Measures may include such activities as seeding of bare slopes; provision of diversion drainage ditches; use of hay bales or straw around catch basins and drainage structures to detain soil; installation of fabric silt fencing around the area to be cleared; construction of detention basins; or limiting the amount of permitted bare ground at anyone time. Guidelines and specifications for revege- tation and erosion control practices for soil-disturbing activities can be developed on a soil-type-specific basis.

The environmental impact assessment for more comprehensive projects and actions, such as long-range management plans for exten- sive acres of national forests or Bureau of Land Management lands, may not be so easily concluded that successful mitigation of soil ero- sion impacts is possible. Plans that will set policy and specific re- quirements for many years regarding the use of land for grazing, timbering, and mining may have serious effects on soil conservation and productivity. Lands that are mismanaged because of incorrect as- sumptions or unforeseeable factors can cause irretrievable and irre- versible loss of soil resources and associated watershed or stream impacts. For this reason, long-term and geographically extensive management plans must be carefully assessed. Periodic checks and

balances must be included to permit reassessments and revisions based on changing environmental factors.

16.4 Soli Suitability

As with geologic features, the evaluation of soils-related impacts often involves assessing the suitability of soils to support the proposed activ- ity or project, or suitability of the proposed project or action given the soil characteristics of the location. For example, if soils are not appro- priate for supporting structures, or maintaining a slope without slip- page, then unsuitable soils may have to be excavated and replaced with other soils, which are then compacted to produce required sup- port characteristics. On the other hand, if existing ground is composed of fill material, it may not be a suitable location for the construction of homes or buildings. The goal of the analyst is to detennine the compat- ibility of the proposed use of land with the characteristics of the soils.

The Natural Resources Conservation Service land-use policy objec- tives, as set forth in Parts 400 to 404 of the General Manual, are as follows:

• Systematically protect agricultural land, including cropland, range- land, and forest land, from unnecessary and irreversible conversion to nonagricultural uses.

• Discourage incompatible uses of land or the construction of unnec- essary encroachments in floodplains and wetlands.

• Promote the use of land within its capabilities to protect natural re- sources and to ensure public health, safety, and welfare.

• Encourage and assist states and local governments in planning for growth and development in coastal areas to protect the coastal re- source base.

As noted in the land-use policies, soil considerations overlap with other areas of impact assessment, such as floodplains, wetlands, or coastal zones, discussed in other chapters of this text.

Legislation and regulations continue to strive for increased compat- ibility in land use with natural soil and geologic conditions. An exam- ple is the Watershed Protection and Flood Prevention Act to provide assistance for persons living in small watersheds and to provide addi- tional treatment and protection of federally owned lands within such watersheds. The Food Security Act of 1985 discontinues certain bene- fits and incentives provided by the Department of Agriculture to per- sons who produce agricultural commodities on highly erodible land or converted wetland.

Although mostly considered as a compatibility assessment, some types of projects affect the chemical or physical characteristics of the soil. Examples are poor agricultural practices, clearing of land cover that produces changes in sunlight and the moisture content of soil, or application of fertilizers or pesticides to crops. Severe soil contamina- tion also can result from spillage of hazardous materials such as fuel oil, acid mine drainage, or leachate from landfills. These types of ef- fects can render soils unsuitable for most uses.

16.5 Farmland

The protection of farmland is directly related to a concern for the rapid conversion of agricultural land, including cropland, forest land, and rangeland, to nonagricultural uses. The conservation of highly productive agricultural land and the maintenance of sustainable food production are goals consistent with the national welfare.

16.5.1 Sustainable agriculture

Sustainable agriculture refers to agricultural practices that, through the use of technology, provide for long-term sustainability of production, profit, environmental quality, and food safety. It is achieved through management strategies which help the producer select hybrids and vari- eties, soil-conserving cultural practices, soil fertility programs, and pest management programs. The goal of sustainable agriculture is to mini- mize adverse impacts to the immediate and off-farm environment while providing a sustained level of production and profit (7 CFR Part 407).

16.5.2 Legislation and definitions

The Farmland Protection Policy Act of 1981, as amended in 1987 (FPP A), has a purpose of minimizing the extent to which federal pro- grams contribute to the unnecessary and irreversible conversion of farmland to nonagricultural uses. The act defines three levels of im- portant farmland: prime farmland, unique farmland, and farmland of statewide or local importance.

Prime farmland, generally, is land that has the best combination of physical and chemical characteristics for production of agricultural crops with minimum input of fuel, fertilizer, pesticides, and labor. The Natural Resources Conservation Service actually uses a number of very specific criteria to designate soil as prime farmland. Prime farm- land can see current use in cropland, rangeland, or forest land, but is not already in, or committed to, urban development or water storage. Prime farmland already in urban use has a density of 30 structures per 40-acre area. Prime farmland committed to urban development must score 160 points or less from the land evaluation and site as- sessment criteria (discussed below).

Unique farmland is land other than prime farmland that produces specific high-value food and fiber crops. Farmland ofstatewide impor- tance is land so designated by state agencies as important in the pro- duction of crops.

Many states also have enacted specific laws and regulations for the protection of agricultural lands. These statewide requirements can be more stringent than federal requirements, and they also would apply to non-federally assisted projects. Sometimes preparation of a sepa- rate farmlands impact assessment report, for review and approval at the state level, is required. The analyst should coordinate at the earli- est possible time with state and local planners and officials to deter- mine any special study requirements.

16.5.3 FPPA criteria

The Farmland Protection Policy Act directs the Department of Agriculture to develop criteria for identifying the effects of federal pro- grams on the conversion of farmland to nonagricultural uses. The DOA's criteria are contained in 7 CFR Part 658 and consist of two parts: land evaluation criterion-relative value, and site assessment criteria.

The Natural Resources Conservation Service provides technical as- sistance to develop state and local agricultural land evaluation and site assessment (LESA) systems. Procedures for developing LESA systems are contained in the Department of Agriculture National

Agricultural LESA Handbook (U.S. Department of Agriculture, Soil Conservation Service, 1983). The LESA system is designed to deter- mine the quality of land for agricultural uses and to assess sites or land areas for their agricultural economic viability. The Handbook provides guidance on land evaluation criteria for cropland, forest land, and rangeland and on site assessment criteria.

Compliance with the Farmland Protection Policy Act is accomplished through use of Form AD-1006, the Farmland Conversion Impact Rating Form. A summary ofform information is shown in Fig. 16.1.

The first part of the criteria, the land evaluation or relative value, is established by state and local officials, with technical assistance from the Natural Resources Conservation Service. Based on soil char- acteristics, groups of soils within a local government's jurisdiction are evaluated and assigned a score between 0 and 100, representing the relative value for agricultural production of the farmland to be con- verted by the proposed project or action compared to other farmland in the same local government jurisdiction. This score is the relative value rating on Form AD-1006.

The second set of criteria for evaluation of farmland conversion im- pact, the site assessment criteria, is used to evaluate specific site characteristics of the proposed project or action. Based on the an- swers to 12 questions, a maximum score of 160 points is possible for a particular site or alternative. The criteria contained in the Farmland Protection Policy Act rule include scoring a proposed site based on consideration of these 12 factors:

Criteria Maximum total points

1. Area in nonurban use 15

2. Perimeter in nonurban use 10

3. Percentage of site being farmed 20

4. Protection pr,ovided by state and local governments 20

5. Distance from urban built-up area 15

6. Distance to urban support services 15

7. Size of present farm unit compared to average 10

8. Creation of nonfarmable land 10

9. A vailability of farm support services 5

10. On-farm investments 20

11. Effects of conversion on farm support services 10

12. Compatibility with existing agricultural use 10

Total possible points 160

For projects that have linear, or corridor-type sites, criteria 5 and 6 are eliminated and criteria 8 and 11 are scored on a scale of 0 to 25 points.

Although the example included above relates to the criteria con- tained within the Natural Resources Conservation Service guide for conformance with the Farmland Protection Policy Act, the analyst should be aware that many local areas have developed specific LESA systems for use in that particular geographic area. These local sys- tems, ifapproved by the NRCS for use in compliance with the FPPA, should be used for the site assessment portion of the analysis.

16.5.4 Interpreting results

The combined land evaluation and site assessment criteria yield a maximum score of 260 points for any particular site or alternative. The highest combined score indicates sites most suitable for protection as farmland. Sites with combined scores of less than 160 points are to be given minimal protection, and no additional sites need to be evaluated. If a site receives a score of 160 points or more, the proposed project or action must be reevaluated to consider (1) the use of land that is not farmland; (2) alternative sites, locations, and designs; and (3) special siting requirements that may preclude the use of an alternative site.

16.5.5 The process

The presence or absence of soil classified as prime farmland, unique farmland, or soils of statewide or local significance is determined through review of applicable soil surveys for the sites or locations of the proposed project or action. The project sponsor fills in part I of Form AD-1006 and forwards the form, with appropriate project alternatives descriptions and mapping, to the Natural Resources Conservation Service. Refer to Fig. 16.2 for a summary of the FPPA compliance process.

Mter review of the information on the proposed project or action, the Natural Resources Conservation Service determines if the site is farmland subject to the Farmland Protection Policy Act. The Natural Resources Conservation Service has 45 days to respond to requests for determinations of farmlands subject to the act. If the Natural Resources Conservation Service does not respond, and further delay would interfere with construction activities, the agency may proceed as though the site were not farmland.

If farmland subject to the act is involved, the NRCS returns Form AD-1006 to the sponsoring agency, with completed parts II, IV, and V, the land evaluation sections of Form AD-1006. The sponsoring agency then applies the site assessment criteria and completes parts III, VI, and VII. Based on the total combined score for relative value (land eval- uation) and site assessment criteria, the agency determines the suitabil- ity of the site for protection as farmland. A copy of the completed Form AD-lO06 must be returned to the NRCS after a decision relating to farmland conversion has been made by the federal sponsoring agency.

16.5.6 Rights of private property owners

The 1987 amendments to the Farmland Protection Policy Act clarified the issue of private ownership and the discretion of the federal agency to provide assistance to convert farmland to nonagricultural uses. The act clearly states that the federal government is not authorized to regulate the use of private or nonfederalland. In a case of a private party or nonfederal unit of government applying for federal assis- tance to convert farmland to nonagricultural use, the federal agency will apply the criteria and recommend alternatives or measures to avoid or minimize adverse effects. If the landowners want to proceed with the proposed project or action, the federal agency may provide or deny the requested assistance. The private parties or nonfederal gov- ernment unit may proceed with the proposed project or action without federal assistance.

Marriott, B. (1997). Environmental impact assessment: A practical guide. New York, NY: McGraw-Hill.