NEPA Process and Specific Requirements - Environmental Impact Analysis: Process and Methods - page 72

practitioners because, “if you don't know where you are going, you will
never know if you have arrived.” Thus the statement gives not only the prac-
titioners, but all other stakeholders a sense of where the process is headed,
and at the end, whether it has been successful.
By simply and concisely stating the purpose and need upfront, not only
in the draft and final environmental analysis documents, but also as part of
all scoping and public involvement efforts, potential stakeholders are able
to determine whether their interests could be affected. This then allows
them to make informed and rational comments on alternatives to be consid-
ered, identify the environmental resources they feel could be affected, and
provide informed input on the scope of the environmental analysis. If the
agency or other entity proposing the action is not clear up front regarding
what they hope to accomplish, they could receive voluminous input during
scoping that is not relevant, yet they would be obligated in the draft EIS,
or similar document, to respond to the comments and explain why they
were not relevant. At the end of the process the purpose and need state-
ment provides the stakeholders, including the courts in the case of a NEPA
analysis, a meter stick to measure accomplishments and judge the success
of the process.
The CEQ may have had in mind a distinction between “purpose” and
“need” when they included both terms in their 1978 guidelines for imple-
menting NEPA (discussed in Section 2.3) but since the concept is presented
by the guidelines in only one sentence, they do not make the distinction
apparent. Early NEPA practitioners attempted to make a distinction between
purpose and need both by exploiting subtleties in the definition and using
the two terms to formulate an alternative evaluation process consistent with
the intent of NEPA. For example, Schmidt (1993) working with the Bonneville
Power Authority on one of the first EISs prepared in accordance with the
1978 CEQ guidelines attempted to interpret CEQ guidance on purpose and
need. His interpretation was that the underlying need represented a problem
to be solved or an opportunity to be exploited by the agency and the pur-
poses as other objectives related to the problem or opportunity. Following
this interpretation, Schmidt (1993) proposed that the underlying need would
define the range of alternatives for the EIS and if an alternative also met the
purpose, it should be retained for a detailed analysis. Others have proposed
satisfying the underlying need as the criterion for retaining an alternative for
detailed analysis in the draft EIS and using the purposes, or agency goals,
as criteria for comparing alternatives and designating a preferred alternative.
In practice, particularly in recent years, the distinction between purpose
and need has generally been blurred and/or lost. A unified purpose and need
statement is typically developed and used to determine the range of alterna-
tives for the draft EIS. Achievement of the statement is frequently measured
by identifying specific criteria that define the purpose and need. For example
if the purpose and need of a proposed action is to relieve traffic congestion
along the main street of a small town, the criteria established to measure