ENVIRONMENTAL IMPACT STATEMENTS

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP79M00467A001100100003-6
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 4
• Document Creation Date: December 16, 2016
• Document Release Date: May 11, 2005
• Sequence Number: 3
• Publication Date: February 10, 1976
• Content Type: MF

EXECUTIVE OFFICE OF THE PRESIDENT
^.OUNCIL ON ENVIRONMENTAL QUALI
Approved For Reese 200505/2xsOlA#le,i7,9MOO467AOW100100003-
WASHINGTON. D. C. 20006
FEB 1 0 1976
MEMORANDUM FOR HEADS OF AGENCIES
SUBJECT: Environmental Impact Statements
During the,past .year .the- Council-,on Environmental Quality,
h
'
as conducted -a
review. of federal.- agency ;implementation
of--the" environmental impact statement (EIS) requirement
of the National Environmental Policy Act (NEPA). That
review has indicated that federal agencies have increasingly
used the EIS process successfully as a means to improve
decisions affecting the environment. Nevertheless, situa-
tions continue to arise in which the impact statement
process has been more an appendage to or justification for
decisions already made than an aid to decisionmaking.
Frequently these failures have been caused or aggravated
by the inordinate and unnecessary length of EISs. Such
documents at best obscure the intent of NEPA and can be
extremely harmful to the environmental impact statement
process. It. is the purpose of this memorandum, therefore,
to reemphasize to all agencies the Council's position on
the appropriate focus, use and length of environmental
impact statements in the federal planning and decisionmaking
process.
An unnecessarily large portion of many EISs has been
devoted to descriptions of the proposed action and the
existing environment. Frequently, EISs follow lengthy,
detailed outlines in order to assure that at least some
treatment, however brief, is given to every subject
conceivably relevant to the proposal. In following this
approach agencies make little or no attempt to rank and
then analyze in depth the most significant environmental
impacts.
There are several reasons why EISs have taken this course:
some EIS authors believe that the EIS itself should be a
comprehensive, highly technical, scientific document;
the voluminous material received by an agency from an
applicant or consultant may prove too time-consuming to
edit; or an agency's lawyers may recommend coverage of
every possible contingency, particularly if the agency
should be sued. The adequacy of an EIS is then measured
by its length.
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These reasons, however, ignore the precept that the EIS
is not an end in itself but is primarily intended to aid
decisionmaking. The statement does not achieve this purpose
when it has such prodigious-bulk that, while. it may serve
some academic purpose, no one at the decisionmaking level
in any agency will ever read it. Since its purpose is to
clarify, not. obscure, issues and to forecast and analyze
significant impacts of a proposal and its reasonable alter-
natives, efforts must be made early in the EIS process to-
weed out unnecessary information. Then, by focusing effort
and attention on meaningful analyses, the legal adequacy
of an EIS will also be supported and enhanced.
It is the Council's position, therefore, that descriptions
of the existing environment and the proposed action should
be included in an EIS only to the extent that they are
necessary for a decisionmaker to understand the proposal,
its reasonable alternatives, and their significant impacts.
The EIS should explain how the scope of the statement and
its level of detail have been carefully delineated in
accordance with the significant environmental issues and
problems foreseen by the agency. Data and analyses in an
EIS should consequently be commensurate with the importance
of the impact as determined by the agency's environmental
analysis. Less important material should be summarized,
consolidated or simply referenced..
These strictures are set forth in section 1500.8(a)CI) of
the CEQ Guidelines on preparation of impact statements which
states that descriptive material in an EIS should be,.
"adequate to permit an assessment of potential
environmental impacts by commenting agencies
and the public. Highly technical and specialized
analyses-and data should be avoided in the. body
of the draft environmental impact statement.
Such materials should be attached as appendices
or footnoted with adequate bibliographic references.
The statement should also succinctly describe the
environment of the area affected..."
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NOV 3 VW
Section 1500.8(b) states that in developing the EIS
"...agencies should make every effort to
convey the required information succinctly...,
giving attention to the substance of the infor-
mation conveyed rather than to the particular
form, or length, or detail of the' statement.."
This section states further that each of the five points
n ET
the statement if it is otherwise adequately
covered in discussing the impact of the proposed
action and its alternatives which items should
normally be the focus of the statement."
In reemphasizing the policy behind these sections of CEQ's
Guidelines it should be noted that the need for manageable
and useful statements does not and should not imply a need
or opportunity to reduce the quality or specificity of
environmental research or study required for an informed
.decision. Environmental conclusions expressed in an impact
statement must still be logically supported by references
to standard texts, scientific literature, appendices, special
studies, or textual material within the statement. Specific
baseline inventories and environmental research will often
be needed initially to determine if there are environmental:
problems that should be analyzed in an impact statement.
While these studies should be made available to the public
and, in the case of a legal challenge, to the courts, they
should be referenced, rather than simply reproduced, in the
EIS itself.
Although the value of the environmental impact statement
process to federal agency decisionmaking has been demonstrated
in the past, improvements in its application are necessary.
Specific efforts to use the impact statement as a management
tool, and to focus the statement on analyses of impacts of
a proposal and its reasonable alternatives will require the
attention and understanding of agency leaders at various
levels. The Council will be glad to assist these efforts
in any way that it can.
Russell W. Peterson
Chairman
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