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alternatives related to different
designs or details of the proposed
action, which would present different
environmental impacts
(e.g., pollu-
tion control equipment on a nuclear
-
plant).
:
In each case, the analysis of alternatives
should be sufficiently detailed and rigorous
to permit independent and comparative -evaluation
of the benefits, costs and environmental risks
of the proposed action and each alternative.
B.
Procedural Issues:
Preparation and Circulation of
Environmental Statements.
227
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necessarily haveimplications for the procedures
that agencies follow in preparing such statements.
It has already been noted,
for example,
that
agencies should make every effort to anticipate
and discuss all major points of view on the
impact of the proposed action in the draft state-
__-ment itself... A
related -procedural -question-con- ro
~ - cerns the extent to which agencies should formally
seek advice from other agencies or members of the
public prior to preparing a draft statement.
ar -
The CEQ guidelines do not require a formalized
_"pre-draft" consultation process.
Indeed, the
reason for requiring a draft statement in the
first place was in order to satisfy the "prior
consultation" requirement found in §102 of the
Act, which refers only to a "detailed statement."
At the same time, however, in order for the draft
- Statement to present an adequate basis for discussion and comment, it must provide a fairly
thorough discussion of the impacts of the proposed
action and alternatives.
Where an agency lacks
the expertise for making such an evaluation, it