Summary of the National Environmental Policy Act and Implementing Regulations - Environmental Impact Analysis: Process and Methods - page 51

60.0%

50.0%

40.0%

30.0%

20.0%

10.0%

0.0%

1970-1998 1998-2004

Year of EIS filing

2007-2012

FIGURE 2.3
Environmental impact statements filed by federal agencies with a rating of Lack of Objection:
1970-1998 (Tzoumis and Finegold 2000); 1998-2004 (Tzoumis 2007); and 2007-2012 (see
Figure 2.2).

creating greater environmental impacts. This is most clearly illustrated by
the long-term record of EISs rated as Lack of Objection by EPA under the
Clean Air Act Section 309 rating process (Figure 2.3). Other rating categories
have changed over time (i.e., Environmental Concern and Environmental
Objection since 1984 and a combined Environmental Restriction prior to
1984), so the trend in other environmental rating categories cannot be as eas-
ily depicted over time. There has been some maturation and change in the
application of the rating system over time, which could account for some of
the temporal variation. However, the drastic decline from 54% of EIS filings
producing no environmental objection during the period 1970 to 1998 to only
26% in the most current period certainly indicates the lack of fulfillment of
NEPA goals.
Equally concerning are the quality of EISs and trends over time in improve-
ment. During 1970-2012, the percentage of EISs determined to have adequate
information and analysis has been relatively constant at 15%-25% with some
agencies showing a decline (Tzoumis 2007). During the same period, the
percentage of EISs rated as inadequate or insufficient has typically been
between 25% and 35%.
The quality of analysis and adequacy of information reported for NEPA
EISs are similar to that reported under other environmental programs. The