a
5S.
3
7
Statements which Cover More than One Action.
Related to the above problem, is the problemof
determining the proper scope of an environ- ~
mental..impact statement in connection with
Federal.programs that may involve a multi--~
plicity.of individual "actions." Section 10(a)
of the CEQ Guidelines makes reference to the
need for such "program" statements in certain
a
cases, and this topic was explored in some
detail at our agency review sessions in
In part, the problem requires
December.
careful agency attention to the definition
of the "action" that the agency is undertaking.
If the definition is too broad and the program
too far removed from actual implementation, the
et |
resulting analysis is likely to be too general
ee
‘to prove useful:.
On the other hand,
-.
an excessively =
>. narrow. definition-is:likély toresaltin- -impact. on EES
= “statements: that-ignéré=the:ceuhuiative-¢ffeets—of-
“=—@ number oF-Snafviduatiy*smalt-actions; *o¥ that.ESae
come so late in the process that basic program
—~
decisions are no longer open for review.
-
Individual actions that are related either
geographically or as logical parts in a chain
-O£f contemplated-_actions may be more appropriately
7 -evaluated-in a single»programstatement. --Such - --<_
a statement also appears appropriate in cdénnection
with the issuance of rules, regulations, or other
general criteria to govern the conduct of a continuing program, or in the development of a new
program that contemplates a number of subsequent
actions.
Examples of such program statements
include the Interior Department's statements on
its oil shale program and on its exploitation of
geothermal steam under the Geothermal Steam Act
of 1970.
In all of these cases, the program
statement has a number of advantages.
It provides
an occasion for a more exhaustive consideration
of effects and alternatives than would be
~