SEPA Nonproject Review Form
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The State Environmental Policy Act (SEPA), chapter 43.21C RCW,
requires all governmental agencies to consider the environmental
impacts of a proposal before making decisions. The Nonproject
Review Form (NPRF) is an optional tool to help the lead agency
evaluate the environmental consequences of a nonproject proposal
and to provide information to decision-makers and the public.
The NPRF cannot be used as a substitute for the environmental
checklist, but may be attached as supplemental analysis.
Applicable information in the NPRF can be referenced in the
environmental checklist without having to repeat the
The NPRF is intended 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 time a nonproject proposal is being contemplated,
i.e. upon identification that a plan, policy or rule is likely
to be needed or is mandated.
The information and analysis in the NPRF should be updated as
the proposal is developed. The number of revisions will depend
on the complexity of the proposal. If the proposal is minor,
one iteration of the NPRF may be sufficient. For more complex
proposals, the NPRF should be revised as analysis is completed
or key issues resolved.
If you are unfamiliar with the form, you should review all of
the questions before providing any answers. This will help
familiarize you with the questions and should avoid duplication
of information. Please note that when a nonproject proposal is
first contemplated, it is often premature to respond to some
questions in the NPRF. Answers may also change as the proposal
is developed and analysis is completed.
NONPROJECT REVIEW FORM
COMPLETED BY: ____________________________________________
PART I - FRAMEWORK
Name of proposal, if any, and brief description:
Agency and contact name, address, telephone, fax, email:
Designated responsible official:
Describe the planning process schedule/timeline:
Location - Describe the jurisdiction or area where the
proposal is applicable.
(Attach map(s) if appropriate):
What is the legal authority for the proposal?
Identify any other future nonproject actions believed
necessary to achieve the objectives of this action.
2. Need and Objectives
- Describe the need for the action. (Whenever possible
this should identify the broad or fundamental problem or
opportunity that is to be addressed, rather than a
legislative or other directive.)
- Describe the objective(s) of the proposal, including any
secondary objectives which may be used to shape or choose
- Identify any assumptions or constraints, including legal
mandates, which limit the approach or strategy to be taken
in pursuing the objective(s).
- If there is no legislative or other mandate that
requires a particular approach, describe what approaches
could reasonably achieve the objective(s).
3. Environmental Overview
Describe in broad terms how achieving the objective(s) would
direct or encourage physical changes to the environment. Include
the type and degree of likely changes such as the likely changes
in development and/or infrastructure, or changes to how an area
will be managed.
4. Regulatory Framework
- Describe the existing regulatory/planning framework as
it may influence or direct the proposal.
- Identify any potential impacts from the proposal that
have been previously designated as acceptable under the
Growth Management Act (GMA), chapter 36.70A RCW.
5. Related Documentation
- Briefly describe any existing regulation, policy or plan
that is expected to be replaced or amended as a result of
the proposal. (Adequate descriptions in section 4.a may be
referenced here, rather than repeated.)
- List any environmental documents (SEPA or NEPA) that
have been prepared for items listed in 4.a. or that provide
analysis relevant to this proposal. Note: Impacts with
previous adequate analysis need not be re-analyzed, but
should be adopted or incorporated by reference into the NPRF.
- Type of document
- Lead agency and issue date
- Where copies can be viewed or obtained
- The portions of the document applicable to the
current proposal and briefly explain relevancy.
Summarize the relevant impact assessment or, provide
reference to discussion(s) in Part II that includes this
- List other relevant environmental
documents/studies/models which have been identified as
necessary to support decision making for this proposal.
6. Public Involvement (Optional)
- Identify agencies with jurisdiction or expertise,
affected tribes, and other known stakeholder groups whose
input is likely to be specifically solicited in the
development of this proposal.
- Briefly describe the processes used or expected to be
used for soliciting input from those listed. [Examples: ad
hoc committees, tribal consultations, interagency meetings,
public workshops or hearings, newsletters, etc.]
PART II – IMPACT ANALYSIS AND ALTERNATIVES
7. Affected Environment
Generally describe the existing environmental landscapes or
elements (e.g., character and quality of ecosystem, existing
trends, infrastructure, service levels, etc.) likely to be
affected if the proposal is implemented. Include a description
of the existing built and natural environment where future “on
the ground” activities would occur that would be influenced by
the nonproject proposal.
Note: When complete, this section needs to provide
information on existing conditions for the elements of the
environment discussed in sections 8 and 9. A list of both the
built and the natural elements of the environment is found in
WAC 197-11-444, and included at the end of this form.
8. Key Issue Assessment
List the identified key issues or areas of controversy or
concern and include a brief statement of why each is a key
issue. For each item listed:
- Identify alternative options or solutions for the
objective or concern.
- Describe the environmental considerations/impacts
relevant to each of the alternatives identified in 8.a.
- Describe reasonable mitigation of adverse impacts
- Identify those alternatives to be carried forward for
- Briefly describe why those alternatives rejected from
further consideration were not carried forward.
9) Proposed Nonproject Action or Alternative Actions
Describe a range of reasonable alternatives or the preferred
alternative that will meet the objective(s). For each
alternative, answer the following questions referring again to
the list of the elements of the environment in WAC 197-11-444:
- If this alternative were fully implemented (including
full build-out development, redevelopment, changes in land
use, density of uses, management practices, etc.), describe
where and how it would direct or encourage demand on or
changes within elements of the human or built environment,
as well as the likely affects on the natural environment.
Identify where the change or affect or increased demand
constitutes a likely adverse impact, and describe any
further or additional adverse impacts that are likely to
occur as a result of those changes and affects.
- Identify potential mitigation measures for the adverse
impacts identified in 9.a and describe how effective the
mitigation is assumed to be, any adverse impacts that could
result from the use of the mitigation, and any conflict or
concern related to the proposal objectives and/or key issues
- Identify unavoidable impacts and those that will be left
to be addressed at the project level.
- Describe how the proposal objectives will or will not be
met if the impacts described in 9.c were to occur.
Note: Alternatives may be rejected at any point in the
process if: they have no environmental benefit, are not within
existing authority, are determined unfeasible, or do not meet
the core objectives.
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 these inconsistencies.
11) Monitoring and Follow-up
- Describe any monitoring that will occur to ensure the
impacts were as predicted and that mitigation is effective,
including responsible party, timing, and method(s) to be
- Identify any plans or strategies for updating this
proposed action based on deviation from impact projections
or other criteria.
WAC 197-11-444, Elements of the Environment
- Earth - Geology, Soils, Topography, Unique
physical features, Erosion/enlargement of land area
- Air - Air quality, Odor, Climate
- Water - Surface water movement/quantity/quality,
- Plants and animals - Habitat for and numbers or
diversity of species of plants, fish, or other wildlife,
Unique species, Fish or wildlife migration routes
- Energy and natural resources - Amount
required/rate of use/efficiency, Source/availability,
Nonrenewable resources, Conservation and renewable
resources, Scenic resources
- Environmental health - Noise, Risk of explosion,
Releases or potential releases to the environment affecting
- Land and shoreline use - Relationship to existing
land use plans and to estimated population, Housing, Light
and glare, Aesthetics, Agricultural crops
- Transportation - Transportation systems,
Vehicular traffic, Waterborne, rail, and air traffic,
Parking, Movement/circulation of people and goods, Traffic
- Public services and utilities - Fire, Police,
Schools, Parks and other recreational facilities,
Maintenance, Communications, Water/storm water, Sewer/solid
waste, Other governmental services or utilities