Environmental Impact Reports on the Internet
by E. J. Koford

The Environmental Monitor
April 7, 1996

The Internet is facilitating grand strides in collaboration and communication. But skeptics continue to regard the information highway as a novelty, with no real economic or tangible benefits. How precisely does this binary stream of electronic whizbang improve our quality of life? The technology is progressing so fast that we are missing the obvious applications. One of the most conspicuous voids is in our own profession of collecting, reviewing, analyzing and producing Environmental Impact Reports (EIRs). I suggest that using the Internet to distribute, comment, store and retrieve EIRs has the potential to save extraordinary costs and resources, to facilitate rapid distribution and review, and improve the tracking and retrieval of EIRs. I further suggest that effective preservation and enhancement of the environment through efficient use of the Internet is in our best interest, and will improve the quality of our lives. These were, after all, the objectives of the California Environmental Quality Act as it was enacted.

The California Environmental Quality Act (CEQA) was approved by the legislature in 1970, closely following the National Environmental Policy Act. The objective of both laws was to require agencies to prepare environmental impact assessments of proposed projects with significant environmental effects, to circulate these documents for public and agency comment before making decisions, and to benefit in the long run from research undertaken for previous projects. CEQA emphasizes these goals in the following three objectives:

CEQA Statutes 21000(e) says: Every citizen has a responsibility to contribute to the preservations and enhancement of the environment".

Section 21003.1(b) Information relevant to the significant effects of a project.... shall be made available as soon as possible by lead agencies, other public agencies, and interested persons and organizations".

Section 21003(d) provides the policy that : Information developed in individual environmental impact reports [shall] be incorporated into a database which can be used to reduce delay and duplication in preparation of subsequent environmental impact reports".

And yet these three objectives remain fundamentally unfulfilled 25 years after the law. While it may be every citizen's responsibility to contribute to preservations", probably fewer than one-in-a-hundred people have ever seen or read an EIR. The relevant information is generally buried deep in several hundreds of pages of text so technical that only the professionals can find and interpret the relevant data. The documents themselves are large and costly to print, meaning that generally members of the public need to go to a public office or a central library to view them. And our public servants and librarians are seldom able to assist members of the public in understanding and interpreting the relevant technical information.

On the second objective, it is the continual complaint of the project proponents that the process takes too long. Even very simple EIRs require 12-14 months, a large part of which is dedicated to producing and distributing paper copies of the voluminous document. The cost of paper production and distribution can double the cost of a large EIR. Our cost to print and distribute a recent EIR for the University of California was nearly $25,000! The cost of individual copies, at 10 to 20 cents a page generally makes them prohibitively expensive for individuals to purchase. Each document can cost $50 or more.

As if one document were not expensive enough, the number of required documents has grown to an extravagant degree. There is the Initial Study, the Notice of Preparation, the Draft EIR, the comments to the EIR, often a Revised Draft EIR, the Final EIR, and commonly a Supplemental EIR. In one recent case a string of lawsuits resulted in at least three draft EIRs being distributed over eighteen months. The costs make it impossible, for all practical purposes, for the citizen to exercise his or her responsibility to participate in the process.

The money spent on reproduction of paper copies is a wasted resource. The time, the labor, the paper, the toner, the photocopy machines all represent scarce resources unnecessarily expended. Once the action is taken, the document serves no further purpose, and the dozens of paper copies of Administrative Drafts and Revised Drafts and Supplemental Final EIRs serve no further purpose. The money that goes into production, reproduction and distribution is money that comes out of diligent research and analysis of the project. Small agencies burdened with large document distributions can only do so by reducing the number of hours they spend collecting and analyzing the data. And small public agencies are funded by the citizens.

On the third objective, the legislators that wrote CEQA envisioned a central repository where EIRs would accumulate until future EIRs would require no more research and analysis than a few hours review of the existing environmental documentation for the area. It was to be the function of this repository to compile and distribute environmental data collected over the years. I believe that was the intent behind creation of the State Clearinghouse. The Clearinghouse is the one repository to which all EIRs are sent. Regrettably, the Clearinghouse has never functioned as either a repository or a library. One cannot go to the State Clearinghouse and look at an EIR filed in Placer County in 1989. Nor can one search the text of EIRs to determine where pine marten surveys have been performed in California. The data in such EIRs is essentially lost to the professional and citizen community. In practice, each EIR relies in large part on a review --generally through the cultural memory of individuals involved with the project-- of relevant EIRs performed during the last several years. In the absence of cultural memory, the EIR starts from scratch to gather and analyze field data, or with a search for titles at the Clearinghouse. Thus while CEQA envisioned an efficient streamlined response to environmental analysis, in reality technical analysts can labor for months to prepare an EIR section, only to discover later in the process that the identical analysis has already been performed for some adjacent property for a previous EIR. Because of the lack of an adequate data tracking system, the substantial professional effort that goes into an EIR is practically lost moments after the document is finalized.

One example of this regrettable loss is in the area of wildlife and natural resources research. In my own field of expertise it is evident that the days when universities and academic institutions performed most of the field surveys and species distribution studies are gone. These institutions fundamentally require that the results of such studies be published in peer-reviewed professional journals. Professional journals have long historical records, regular cross indexing and multiple copies deposited in every academic and scientific library in the world. Sophisticated electronic databases such as Biosis, Chemical Abstracts and the Science Citation Index ensure that virtually any student can find, in a few hours, every relevant reference to the distribution and behavior of any species in which he or she is interested.

In these austere days, university and academic institutions can afford to fund precious little of this kind of basic research. Even the National Biological Survey, chartered with the objective of performing a nationwide census and description of wildlife populations is virtually bankrupt by lack of congressional support. Project developers, both private and public, however, continue to bear the onus of performing baseline biologic research. Every hydroelectric power plant, every lumber plant, every housing subdivision, and every ski area expansion requires that baseline biological surveys be performed and documented in the EIR. The unfortunate aspect is: these documents, termed gray literature are virtually never reported in the professional literature. Since only peer-reviewed professional journals are entered into the substantial academic databases, THERE IS NO RECORD OR INDEX TO THE EIRS THAT CONTAIN THIS INFORMATION.

The fundamental vision of CEQA, that this information would be available in a database to avoid delay and substantial duplication of effort has never been realized. Furthermore, the only remaining reliable source of information regarding the extent of our natural resources is being recorded in a book that is not accessible, retrievable or indexed. Remember, the function of the EIR is to document the analysis until the decision is produced. EIRs rarely are preserved more than five years after the project is approved.

The solution to these three problems, to me is at hand, readily available and within our technological grasp... in the Internet.

Consider how an EIR filed and made available over the Internet would meet the three objectives of CEQA.

An EIR filed over the Internet would be widely accessible at minimal cost.

The most recent statistics indicate that approximately one in six people in the United States actively use the Internet, and the proportion is growing daily. Rather than send out hundreds of documents by mail, the lead agency using the internet would run an advertisement in the local newspaper, or send out one page letters to interested parties announcing that the EIR in question would be available at a specific URL (e.g. Internet address) on and after a given date. Anyone with Internet could then access, review and even retrieve the document, as well as any of the relevant appendices or other information with no more than a telephone call and a few strokes on the keyboard. Even those with the most limited access would be accommodated because many universities, libraries and schools are now providing free Internet access for their patrons. Cost would not be a deterrent, as even the largest EIRs require less space for text in electronic format than a single photograph.

Not only would the information be widely available but more accessible. The typical reader is only interested in a small portion of the EIR and wading through chapters of fine print to find the issue of concern is daunting. Often, an irate comment to an EIR is responded to simply by indicating that the reader did not find a pertinent reference to the issue in some other portion of the document. On the Internet, a concerned citizen could search the document electronically and find every occurrence of the words noise, or air quality for example. Such a search would immediately lead the reader to the pertinent discussion in the Introduction, Setting, Impacts, Mitigation Measures, Conclusions and Appendices without miring them inextricably in other portions of the document.

Comments to the EIR could be accommodated more easily as well, in that the Internet EIR would have a hypertext link at the end of every section that would lead the reader into an e-mail link back to the lead agency or the author of that section. Such links are common in electronic catalogs and response forms throughout the Internet, and encourage participation by their simplicity and ease of use. The reviewer has no burden of typical written correspondence. And the response arrives within seconds to the lead agency, and if desired, to the preparing consultant. If the hypertext link appears on each page or section, the comments would automatically be sorted according to the section that they address. This obviates the laborious task of collecting, organizing and distributing comments to the draft EIR.

The Internet EIR would be available to all responsible agencies and interested parties instantaneously, without the usual delays associated with copying and distribution of paper documents.

From the moment the lead agency released the EIR onto the Internet, every commenting agency and citizen would have access to the information, whether day or night, weekend of holiday, whether at the office or skiing in the French Alps. The material would be accessible and available instantly. This is an advantage, not only for the Draft EIR, but for earlier internal drafts. There is substantial time spent in preparing the Draft EIR, wherein an Administrative Draft and other early versions are transferred among the preparing consultants and the various agencies for internal review. Each of these transfers is preceded by paper production, reproduction and transmission (generally by mail, overnight mail or fax) which add to delays, costs and losses in delivery. The decrease in delivery time and the EIR arriving in an electronically searchable format would potentially allow various agencies to complete their review more efficiently and in less than the current 30- and 45-day review periods. Shortening the review periods would shorten the overall process substantially.

The Internet EIR would be simple to store, retrieve, search and extract in an electronic database, allowing subsequent EIRs to find and use the previous information to avoid unnecessary delay and duplication.

Consider that with today's technology a 300-page EIR, with graphics, and up to 10 photographic images would occupy approximately 2 million kilobytes of memory (uncompressed). A single five-inch compact laser disk (CD ROM) could hold approximately 350 such documents and recent advances promise to make data storage capacity even greater. Such CD Roms could be comprehensively searched easily and quickly for key words, biological baseline data or other ancillary information. According to the State Clearinghouse there were approximately 600 EIRs filed in California in 1995. Consider that the entire text and graphics of all the EIRs ever written could be held in less space than a boxed set of the complete Wagner operas!

In this brief essay, I have tried to represent that attaining at least three of the objectives of CEQA that have alluded us for 25 years are now within our technological grasp. In addition to attaining the intended goals, implementing this solution would save untold hours of time, staggering sums of money and tons of now-wasted resources. All it requires now is the boldness of the first step... for an agency with vision to require that the next EIR be filed ON THE INTERNET!

E. J. Koford is a Senior Biologist with EIP Associates.