Compendium of Useful Practices

Programmatic Analysis and Tiering

This case study is provided as an example of programmatic and subsequent tiered NEPA analyses and documents.

Project: Shoreline Management Initiative (SMI)

Agency: Tennessee Valley Authority (TVA)

Point of Contact: Harold Draper, (865) 632-6889, hmdraper@tva.gov

Dates: Began: 1994 Ended: Ongoing

Project Description: In 1994, TVA began an initiative aimed at determining a new policy for residential shoreline permitting on its system of dams and reservoirs in seven states - the Shoreline Management Initiative (SMI). The project responded to increasing numbers of applications for residential shoreline alterations such as docks, boathouses, and retaining walls. TVA analysis showed that half of the shoreline could be developed within the next 25 years if current trends continued. TVA decided to conduct a programmatic EIS on the SMI policy seeking to better protect shoreline and aquatic resources while allowing residents reasonable water access.

As alternative development proceeded, it became obvious that the development of permitting standards could not be easily separated from decisions on where and when to allow residential shoreline alterations for new subdivisions. In the Record of Decision (ROD), TVA decided to continue to allow docks and other alterations along shorelines now available for residential access and to establish uniform standards for the alterations. For those reaches of the shoreline where residential access rights did not exist, TVA established a policy to ensure that no more than 38 percent of the shoreline would be developed for residential access. A no net loss evaluation procedure was established that linked the shoreline management policy to an ongoing reservoir land planning process. When public shore land is proposed to be made available for residential use, the no net loss evaluation procedure is initiated. For a given proposal, TVA seeks to "compare the ecological, recreational, and other amenities of the properties involved in the proposal with the public and resource values of the TVA land over which the access rights are requested."

In the reservoir land planning process, TVA land on reservoirs is allocated to planning zones. Projects on the reservoirs are reviewed for consistency with the planning zone, using site specific environmental reviews. Lands that are allocated to natural resource management uses are further planned for specific forest, wildlife, and public use management practices. The reservoir land allocation process is then further tiered to natural resource management plans which determine specific forest, wildlife, and public use management.

Value as a Practice:

Results: The programmatic level review established direction for the program and provided a high level analysis which facilitates preparation of tiered site specific documents. The overall policy and environmental considerations are now linked to site specific decisions and analyses providing a better picture of the potential cumulative impacts and health of the shoreline and associated aquatic resources. This process promotes efficiency because a common set of regulations and policies are established first, and subsequent proposals are reviewed for consistency with these standards before undergoing further environmental review.

Challenges Overcome: TVA overcame initial reluctance to conduct programmatic reviews. The reluctance was due to the perception of excessive costs and uncertain benefits. TVA successfully demonstrated the long term benefits of such an approach and the improvements to agency decision frameworks.

Challenges Remaining: Due to budget considerations, the planning has not been completed for all of the reservoirs. However, the shoreline permitting standards are still in effect for the other reservoirs as is the no net loss evaluation procedure.