Non-Project Review Form (NPRF)
NOTE: The following is a draft of a possible nonproject
review form to replace the current environmental checklist and
supplemental sheet D for nonproject actions. Revisions are
likely to occur before a final draft form is circulated for
SEPA Non-Project Review Form (NPRF)
The nonproject review form (NPRF) is to be used concurrently
with the development of a nonproject proposal. To achieve
maximum effectiveness and efficiency, the initial use of the
form should begin at the same time as a nonproject action is
being contemplated, i.e., upon identification that a plan,
policy or rule is likely to be needed or is mandated.
Iterative process: The form is designed so that as a proposal
is developed, the form is updated and detail is added. When a
complete draft proposal is ready for public review, or review by
an intermediary governmental body (e.g., a planning commission),
the form should be at a comparable draft state, similar to a
draft environmental impact statement (DEIS).
Initial completion of the form: All questions and requests
for information should be reviewed when a nonproject proposal is
contemplated, recognizing that at this stage it is premature to
respond to some questions and some of the answers will change as
the proposal is developed. Generally, at the initial stages,
Part I of the NPRF can be fully completed and the first several
questions in the remainder of the sections can be preliminarily
PART I - BACKGROUND
- Name of proposal, if any, and brief description.
- Agency and contact name, address, telephone, fax, email
- Designated responsible official
- Description of the planning process schedule/timeline
- Location - Describe the jurisdiction or area where the
proposal is applicable.
- (Attach map if appropriate)
- What is the legal authority for the proposal?
2. Need and Objectives
- Describe the problem to be addressed and the need for
- Describe the primary objective(s) of the proposal.
- Are there any other objectives, including environmental?
If so, describe.
3. Related Documentation
- Identify and briefly describe any similar or related
plan, regulation, policy, etc., currently in effect
governing this geographic area and that contains the means
to further the primary objective.
- Is this proposal likely to result in an amendment to, or
replacement of, any existing regulation, policy or plan?
- List any environmental documents (SEPA or NEPA) that
have been prepared for items identified in 3(a) above.
NOTE: impacts with previous adequate analysis need not be
re-analyzed, but should be incorporated by reference into
the NPRF.) Identify the:
- Type of document,
- Lead agency and issue date,
- Where copies can be obtained, and
- A brief summary of the primary objectives, impact
analysis from the alternatives being considered, type of
mitigation considered, and monitoring process.
- List any environmental
documents/studies/models that need to be or have been
prepared for fulfilling data/information gaps prior to
4. Planning Processes/Approaches & Public Involvement
- Identify any assumptions or constraints, including legal
mandates that limit the approach or strategy to be taken in
pursuing the objectives.
- If there is no legislative or other mandate that
requires a particular approach, what type of approaches
could reasonably achieve the objectives?
- Why was the approach presented in the proposal selected?
- Who are the known primary stakeholders?
- What other agencies are involved and for what reason?
- What types of processes will be used for soliciting,
evaluating, and documenting input from stakeholders,
agencies, tribes and the public?
- If different from above, briefly describe the
processes used in addressing the concerns and comments of
the public and other interested parties.
5. Long Range Consequences
- If the primary objectives are met, is it likely that the
nonproject action will direct or encourage physical changes
to the environment?
- Broadly describe the type and degree of likely changes
in terms of increase in development and infrastructure or
changes to how an area will be managed.
- Describe any future options that will be precluded if
the primary objective is met.
What other nonproject actions will be necessary to achieve
the objectives of this action?
6. Existing Environment
- Generally describe the existing environmental
landscapes or elements (i.e., status or quality of
ecosystem) likely to be affected if the proposal is
implemented. Include a description of the existing
environment where resulting "on the ground" activities may
occur and areas and facilities likely to be impacted. The
following should be included, as appropriate:
- Native vegetation & forested areas
- Riparian, floodway, and conservancy corridors
- Groundwater recharge areas
- Surface water systems: lakes, streams and
- Endangered/threatened species in or near the
- Stormwater and detention ponds systems
- Hazardous/human waste storage areas
- Commercial, industrial and residential areas
- Shoreline and wetland alterations
- Percent impervious surfaces (approximate)
- Unique features, including historic and cultural
- Transportation and public utilities
- Regulatory Environment
Describe the existing regulatory planning framework as it
may affect or guide the proposal, such as:
- Urban Growth Areas
- Shoreline Management Areas
- Current Zoning
- Potential or existing critical areas, resource
- State and/or federal environmental regulations
PART II – IMPACT ANALYSIS AND ALTERNATIVES
7. Key Issues/Questions, Alternatives & Preliminary
- Identify the current known or anticipated key
environmental issues or areas of controversy or concern.
Include a brief statement of why this is a key issue.
- Identify alternative solutions or responses for each key
issue/concern listed above.
- Identify environmental considerations/impacts relevant
to each of the alternative solutions/responses identified.
- What choice (preliminary decision), if any, was made
regarding each key issue?
- Identify any choice that will commit the agency and that
may have an adverse effect on the environment.
- Which alternatives will be carried forward for further
- For those choices not carried forward briefly describe
8. Proposed Nonproject Action or Alternative Actions
Describe a range of alternatives or the preferred alternative
that will meet the objectives.
9. Cumulative/Indirect Impacts and Mitigation
- If this alternative were fully implemented, how and
where would it direct or encourage an:
- Increase in infrastructure?
- Increase in development?
- Increase in demand for public services?
- What are likely impacts from new development,
redevelopment, changes in land use, density of use, and
management practices resulting from this proposal?
- Removal or degradation of native or aquatic
- Increase in impervious surfaces?
- Removal/diversion of surface waters?
- Limits to the ability of groundwater or aquifers to
- Encroachment on riparian corridors, floodway zones,
conservation priorities, shoreland designations, and
other regulatory setbacks/buffers?
- Degradation of environmental health, i.e., increase
- Degradation of other ecological processes, e.g.,
- Limits on the quantity/quality of public drinking
water and air supply?
- Burdens on existing stormwater, detention ponds,
traffic patterns, storage of hazardous/human waste
capacities, and other infrastructures?
- What are potential mitigation measures for these
- Will the intent of the proposal still be met if these
PART III – IMPLEMENTATION CONSIDERATIONS
10. Consistency of the proposal with other plans, policies
- Internal consistency - If there are internal
inconsistencies between this proposal and your agency’s
previously adopted or ongoing plans and regulations,
identify any strategies or ideas for resolving these
- External consistency - If there are external
inconsistencies between this proposal and adopted or ongoing
plans and regulations of adjacent jurisdictions and/or other
agencies, identify any strategies or ideas for resolving
11. Unavoidable impacts and impacts to be addressed later.
- For GMA actions, what impacts from the proposal have
been designated as acceptable under chapter 36.70A RCW?
- Identify what impacts have been left to be addressed at
the project level (i.e., thresholds which trigger further
environmental analysis at the project level).
12. Monitoring and Follow-up
- How will the proposed action be monitored to ensure the
impacts were as predicted and the mitigation is effective?
Who will do the tracking? How will it be done? etc.
- How will the impacts of the proposal be measured in
relation to any benchmarks, performance standards and/or
thresholds identified in the proposal?