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Title: A model for determining when an analysis contains sufficient detail to provide adequate NEPA coverage for a proposed action

Technical Report ·
DOI:https://doi.org/10.2172/10120437· OSTI ID:10120437

Neither the National Environmental Policy Act (NEPA) nor its subsequent regulations provide substantive guidance for determining the Level of detail, discussion, and analysis that is sufficient to adequately cover a proposed action. Yet, decisionmakers are routinely confronted with the problem of making such determinations. Experience has shown that no two decisionmakers are Likely to completely agree on the amount of discussion that is sufficient to adequately cover a proposed action. one decisionmaker may determine that a certain Level of analysis is adequate, while another may conclude the exact opposite. Achieving a consensus within the agency and among the public can be problematic. Lacking definitive guidance, decisionmakers and critics alike may point to a universe of potential factors as the basis for defending their claim that an action is or is not adequately covered. Experience indicates that assertions are often based on ambiguous opinions that can be neither proved nor disproved. Lack of definitive guidance slows the decisionmaking process and can result in project delays. Furthermore, it can also Lead to inconsistencies in decisionmaking, inappropriate Levels of NEPA documentation, and increased risk of a project being challenged for inadequate coverage. A more systematic and less subjective approach for making such determinations is obviously needed. A paradigm for reducing the degree of subjectivity inherent in such decisions is presented in the following paper. The model is specifically designed to expedite the decisionmaking process by providing a systematic approach for making these determination. In many cases, agencies may find that using this model can reduce the analysis and size of NEPA documents.

Research Organization:
Westinghouse Hanford Co., Richland, WA (United States)
Sponsoring Organization:
USDOE, Washington, DC (United States)
DOE Contract Number:
AC06-87RL10930
OSTI ID:
10120437
Report Number(s):
WHC-SA-2723; ON: DE95006767; TRN: 95:002047
Resource Relation:
Other Information: PBD: Nov 1994
Country of Publication:
United States
Language:
English