RECOMMENDATIONS FOR IMPROVING
AGENCY NEPA PROCEDURES
Substantive “*ssues:
The Required Content of Environmental
Statements.
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Duty to Disclose Full Range of Impacts.
Court decisions under the National Environmentai.
oI.
Policy Act have established that the "detailed"
7
statement referred to in section 102 of the Act
must thoroughly explore all known environmental
consequences of and alternatives to major proposed
actions even though this may lead to consideration
of effects and options outside the agency's actual
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control.
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Meant to ensure that relevant ‘officials and the: -.7 ~~ "=
public are alerted to the environmental impact of
Federal agency action.
See EDF v. Corps of
Engineers, 2 ERC 1260, 1267 (E.D. Ark. 1971).
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Furthermore, the range of impacts which must be= 0 2
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area of agency jurisdiction or expertise.
NEPA in
essence adds a new mandate to the enabling legislation of all agencies, requiring the development
of environmental awareness for the full range of
impacts of proposed agency action. By failing to
discuss reasonably foreseeable impacts or by discussing those impacts in a perfunctory manner, an
agency defeats the purpose of the statement and lays
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