Summary of the National Environmental Policy Act and Implementing Regulations - Environmental Impact Analysis: Process and Methods - page 50

EU3 - 2%

EO2 - 5%

EO1 - 1%

LO - 26%

LO - Lack of objections
EC1 - Environmental concerns,
adequate information
EC2 - Environmental concerns,
insufficient information
EO1 - Environmental objections,
adequate information
EO2 - Environmental objections,
insufficient information
EU3 - Environmentally unsatisfactory,
inadequate information

EC1 - 11%

EC2 - 55%

FIGURE 2.2
U.S. EPA ratings for a subset of federal agency submittals: June 2007 to June 2012.

1998 to 2004. The number of EISs rated inadequate was low and highly vari-
able from 1970 to 1998 and this pattern continued in the more recent period.
The relationship of adequate to inadequate rating remained similar in the
two periods with the number of inadequately rated EISs high for most agen-
cies in most years.
Based on her research and interviews with NEPA practitioners within
agencies, Tzoumis commented that the increased availability of information
was a mixed blessing. Because so much information was readily available
they felt obligated, particularly in response to public comments, to consider
all the information. This tended to dilute their focus on the critical issues.
The interviews also revealed a general feeling among practitioners that
the EISs and the entire NEPA process were somewhat compromised by the
necessity to be both responsive and clear to the public and to provide deci-
sion makers with a solid and verifiable scientific/engineering/social analysis
that was conclusive. The future challenge is to better balance these multiple
objectives.
The evaluations of Tzoumis and Finegold (2000) and Tzoumis (2007)
and the analysis presented above when viewed in combination depict
a disconcerting trend that seems to be continuing. There is a commit-
tee of the broad based and highly respected professional society, National
Association of Environmental Professionals that produces an annual report
on NEPA (www.naep.org). These annual reports track EPA's EIS ratings and
reflect the same and continuing trends described above. EISs appear to be
declining in quality and projects proposed by federal agencies appear to be