NEPA Process and Specific Requirements - Environmental Impact Analysis: Process and Methods - page 70

TABLE 3.1
NEPA Environmental Assessment (EA) Compared with Environmental Impact
Statement (EIS)

EA EIS

Length Can be as few as 6-10 pages;

typically around 50; or
can approach the length of
an EIS

150-page limit recommended;
can be up to 300 for complex
actions

Time to Prepare Typically a few months Rarely less than a year and

typically 1.5-2 years

Data Requirements Generally relies on existing

data and field observations

Original data collection
almost always conducted

Preparation Team General NEPA practitioner

prepares EA, frequently
with input from technical
experts in one or two critical
areas

Multidiscipline team required
with a senior NEPA
practitioner coordinating.
Also public participation,
legal review, and other
expertise involved.

Public Participation and
Availability

Information available to
public but review, comment,
and participation
procedures at the discretion
of each agency

Mandatory review, comment,
and public hearing/meeting
requirements

Review and Comment Largely at discretion of

agency; draft document not
required.

Specific requirement with
public review and comment
of draft EIS required.

Alternatives Minimal treatment (see text) Key component of EIS

Mitigation Can be used and useful in

certain cases (see text)

Must be included in the
process and evaluated fully

Cost Typically in the tens of

thousands of US dollars

Rarely less than a million
U.S. dollars and scientific
investigations alone can run
up to a million U.S. dollars

Final Outcome Finding of no significant

impact OR prepare an EIS

Record of Decision

605 F. Supp. 2d 263 (D.D.C. 2009), it was held that NEPA public participation
requirements for the EAs were met even though the agency did not circulate
the EAs for notice and comment. “[T]he agency has significant discretion in
determining when public comment is required with respect to EAs.”
In compliance with CEQ Regulations and similar to an EIS, the EA must
include a no-action alternative, but some valid EAs have just the two alter-
natives, proposed action and no action. On the surface it appears that this
subverts the NEPA intent of using environmental considerations and impact
mitigation to compare alternative approaches to implementing the pur-
pose and need. But the rationale is that the proposed action in an EA has