4 / j 2 itself open to the charge of non-compliance with the Act.* In order to ensure full compliance with this require- ment it is desirable that agencies develop in advance a list of the typical impacts of those classes of actions that the agency regularly takes. In developing such a list, agencies are reminded that impacts include not only direct effects, but also secondary effects such as "the effect of any possible change in population patterns upon the resource base, including land use, water, and public services, of the area in question." CEQ Guidelines §6(a) (ii). tone By giving consideration to such impacts agencies should also be able to develop an increasingly specific set of standards for determining whatmm - “5 gonstitutes. “nia jor,“envirenmentally-Teigniticantt=== vaections. Application. o£ such standaras to the .. —.- “normal range of agency-aétions willmake“possible ~*~ == earlier and more accurate. identification of actions subject to the §102 requirement. - ee “ - a saa eae oe : _ ee ee - = aw Se eee . . *See, e.g., Calvert Cliffs v. A=ZC, 2 ERC 1779, 1782 (D.Cc. Cir. 1971) (purpose of statement is to aid agency in its decision and to fully inform other interested agencies and the public of environmental consequences); EDF v. Corps of Engineers, 2 ERC 1260, 1267 (E.D. Ark., 1971) (statement must alert President, CEQ, public, and Congress to all known possible environmental consequences); EDF v. Hardin, (D. D.C. 1971) 2 ERC 1425, 1426 (agency must undertake research in planning stage adequate to expose potential environmental impact); Ely v. Velde, 3 ERC 1286 (4th Cir. 1971) (genuine rather than perfunctory compliance with NEPA requires agency to explicate fully its course of inquiry, its analysis and its reasoning); NRDC v. Morton, 3 ERC 1558, 1562, (D.c. Cir. 1972) (statement is for the guidance of ultimate decisionmakers -- Congress and the President -- as well as agency, _ - ft __ and must provide discussion of all reasonable alternatives); Greene County v. Frc, 3 ERC 1595, 1600 (2d Cir. 1972) (statement must present “a single coherent and comprz2hensive environmental an