From proposal to decision: Suggestions for tightening up the “NEPA process”

Abstract Although the process of documenting compliance with NEPA (the National Environmental Policy Act) requires no drastic revisions, it can be managed more rigorously. Suggestions for revision can be grouped under five major steps: 1) getting a complete proposal from the applicant; 2) getting the decision-making process onto the right decision-making path; 3) modifying the applicant's proposal 4) going down a shorter path through the EA/FONSI (environmental assessment and finding of no significant impact) or through categorical exclusion review; and 5) going down the longer path through the EIS. Step 2 is perhaps the most critical, because there a decision must be made whether to write an EA/FONSI or an EIS, on the basis of whether the proposal would “significantly affect … the … environment.” In the past, this decision has not always been made promptly or rigorously. Accordingly, we suggest that the agency responsible for NEPA compliance should develop a system (a “black box”), consisting of a core group of specialists working with an interdisciplinary team, using sophisticated techniques for modeling impacts and directing both their research and their writing according to the concept of significance. By determining more efficiently and reliably whether the impacts of a proposal would be significant, such an approach would improve management of the total process.