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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
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vaections.
Application. o£ such standaras to the ..
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“normal range of agency-aétions willmake“possible ~*~ ==
earlier and more accurate. identification of actions

subject to the §102 requirement.

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*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,

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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

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