Defining the no action alternative for NEPA document of continuing actions
- Oak Ridge National Lab., TN (United States)
Environmental professionals today must address many issues that might not have been foreseen by developers of the National Environmental Policy Act of 1969 (NEPA) or the President`s Council on Environmental Quality (CEQ) regulations for implementing NEPA. One issue is the definition of the no action alternative for NEPA documentation of continuing actions. The CEQ regulations do not define the no action alternative, but merely state that NEPA analyses shall {open_quotes}include the alternative of no action{close_quotes}. For NEPA analyses of newly proposed actions, the practical definition of the no action alternative is clear (i.e., the agency will not implement the proposed action or alternative actions). However, the practical definition for NEPA analyses of continuing actions is not so clear. To clarify the definition of the no action alternative for continuing actions, particularly those that involve agency decisions about relicensing existing projects or continuing to operate existing programs or facilities. In trying to clarify the definition of the no action alternative for continuing actions, this paper examines the function of the no action alternative for NEPA analyses in general. Pertinent issues include how the definition of the no action alternative affects the selection of the baseline for environmental analysis and whether inclusion of the no action alternative really forces agencies to consider no action as a realistic alternative. To address these issues, this paper begins with a discussion of relevant legal decisions involving the no action alternative in NEPA analyses. The paper then examines some agency NEPA regulations and recent NEPA documents to provide examples of how some agencies address the no action alternative for continuing actions. Finally, the paper suggests definitions of the no action alternative for continuing actions and methods for addressing no action as a realistic alternative.
- Research Organization:
- National Association of Environmental Professionals, Washington, DC (United States)
- OSTI ID:
- 125993
- Report Number(s):
- CONF-9506115-; TRN: 95:006735-0088
- Resource Relation:
- Conference: 20. National Association of Environmental Professionals annual conference and exposition: environmental challenges - the next twenty years, Washington, DC (United States), 10-13 Jun 1995; Other Information: PBD: 1995; Related Information: Is Part Of Environmental challenges: The next 20 years. Proceedings; PB: 932 p.
- Country of Publication:
- United States
- Language:
- English
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