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SEPA checklist guidance, Section D: Nonproject actions

Our guidance helps applicants complete Section D of the SEPA environmental checklist required under state SEPA rules.

D: Supplemental Sheet for Nonproject Actions

Nonproject actions are governmental actions involving decisions about policies, plans, or programs containing standards for controlling use or modifying the environment, or will govern a series of connected actions. Nonproject action analysis provides an opportunity to evaluate planned actions before projects begin and permits applications are prepared. The early SEPA analysis results in a more streamlined permitting process when a planned action does occur as the impacts have already been analyzed.

General Guidance for Nonproject Actions

The procedural requirements for SEPA review of a nonproject proposal are the same as a project proposal. Environmental review starts as early in the process as possible when there is sufficient information to analyze the probable environmental impacts of the proposal. The first step is usually to complete an environmental checklist (including Part D, Supplemental Sheet for Nonproject Activities), unless the lead agency has already determined that an environmental impact statement is needed or SEPA has already been completed.

Whenever possible, the proposal should be described in terms of alternative means of accomplishing an objective WAC 197-11-060(3)(a). For example, a statewide plan for use of chemicals to treat aquatic vegetation could be described as a plan to control aquatic vegetation. This would encourage the review of various alternatives for treating vegetation in addition to the use of chemicals. This might include a review of biological or mechanical methods, or a combination of the various methods.

If the nonproject action is a land-use decision or similar proposal that will govern future project development, the probable impacts need to be considered of the future development that would be allowed. For example, environmental analysis of a zone designation should analyze the likely impacts of the development allowed within that zone. The more specific the analysis at this point, the less environmental review needed when a project permit application is submitted.

Only government agencies can initiate nonproject action review and requirements vary by jurisdiction. If you have additional questions please contact the Office of Regulatory Assistance or contact sepahelp@ecy.wa.gov.