GAO Report on NEPA Analyses

The GAO has released a report, “National Environmental Policy Act: Little Information Exists on NEPA Analyses.” Lots to digest! Here are three items, for example, that may be of interest:

* “… the Forest Service reported that 78 percent of its 14,574 NEPA analyses from fiscal year 2008 to fiscal year 2012 were CEs, 20 percent were EAs, and 2 percent were EISs.”

* “… the Forest Service reported that its 501 EAs in fiscal year 2012 took an average of about 18 months to complete.”

* “The little governmentwide information that is available on CEs shows that they generally take less time to complete than EAs. DOE does not track completion times for CEs, but agency officials stated that they usually take 1 or 2 days. Similarly, officials at Interior’s Office of Surface Mining reported that CEs take approximately 2 days to complete. In contrast, Forest Service took an average of 177 days to complete CEs in fiscal year 2012, shorter than its average of 565 days for EAs, according to agency documents.”

More comments on the report are welcome.

4 Comments

  1. As usual, dense fine print. But the USFS metrics look fundamentally more adverse than other agencies for some STRANGE reason, and I can’t help but think the agencies are too busy jumping through NEPA hoops to actually document how many hoops they jumped through — not enough funding and/or staff for THAT, eh?
    Thanks for the link, Steve. I need it for a rant on the Farm Bill HFRA modifications inserted by Bennet and Udall…..you know, the money that will have the mills churning and bring the economy back to life despite the worst efforts of the REITs?

  2. Thanks for pre-digesting this Steve. I guess the distribution of CE/EA/EIS seems about right to me for the way NEPA is supposed to work.

    I’ve never thought it made much sense to compare Forest Service NEPA work to the rest of the government because most agencies aren’t proposing to dig up your playground. Also, if an agency is aggressive about what it tries to cover with CEs, it’s not surprising that they would be more challenging to complete.

    I agree it takes funding to track where the funding goes, and it’s not worth doing that unless it’s a pretty big problem. (That’s why I question the attempts to legislate more record-keeping of litigation costs.)

    • Several times in the past I’ve looked at CE proposals, and just shaking my head that someone has the gall to think they could “sneak” such a thing through. Maybe it worked a few times in the past but, today’s eco-lawyers are sharper than back in the 90’s. *wink*

      I wonder if a CE could be specifically-crafted to include large areas of similar eco-types, for limited, smaller tree thinning projects. Could that be a response for making projects like 4FRI even bigger? Of course, such a thing would have to be vetted by both sides, and meticulously limited, using site-specific criteria. Such a CE could be designed solely to increase acres treated, while avoiding as many eco-issues, as possible. “Avoiding” would be the keyword, there, meaning not including anything controversial.

  3. I think it would be wise to look at the actual projects being CE’ed by the different agencies. DOE CEs might cover repaving a road in a “sooper sekrit” nuke facility where the public is excluded. FS CEs on the other hand might be logging next to a dispersed camp that people have a deep attachment to.

    If FS CEs take longer, maybe it’s an indication that the FS should be doing EAs.

    “Days per CE/EA/EIS” is not a terribly helpful measure of time and effort. Much of that time the paperwork is just sitting somewhere waiting for the next step to be taken, or waiting for public input. It’s not like the whole ID Team is working full time on the document during the 18 month period.

Leave a Reply

Your email address will not be published. Required fields are marked *

You may use these HTML tags and attributes: <a href="" title=""> <abbr title=""> <acronym title=""> <b> <blockquote cite=""> <cite> <code> <del datetime=""> <em> <i> <q cite=""> <strike> <strong>