How to Review a Draft Environmental Impact Statement (DEIS)
© Copyright 1984, David E. Ortman
[Note, this file may be copied so long as author credit is given.]
1.The Council on Environmental Quality has issued EIS regulations under the National Environmental Policy Act. These can be found at 40 Code of Federal Register (CFR) Parts 1500-1508. In addition, each Fe
deral Agency has adopted its own EIS regulations.
Agency preparation of a Draft Environmental Impact Statement (DEIS) begins with a scoping notice. This identifies the impacts and alternatives that the DEIS will address. It is extremely important that citizens participate in the scoping process. I
f you have a feasible alternative, it may become part of the DEIS. In addition, it is more difficult to raise environmental issues after the DEIS has been issued if no one has raised them as part of the scoping process.
2. Skim the DEIS. Locate and mark the actual impact statement from what may be several Appendixes.
3. The impact statement is divided into four main parts: a) Purpose of and Need for Action; b) Alternatives including Proposed Action (if known); c) affected Environment; and d) Environmental Consequences.
4. Your job as a reviewer is to help the agency produce a better environmental impact analysis. With a colored marker read through the DEIS carefully. Make notes in the page margins and draw arrows to the following:
- Terms, concepts or anything else that yo do not understand. An EIS should be understandable.
- Incorrect information, misstatements, lack of data or contradictions in the text (Note page numbers of contradictory statements). An EIS should be factually correct.
- Bias or slanted conclusions. An EIS should be free from bias or opinion.
5. Examine carefully graphs and other figures to make sure that they are clear, understandable and correct.
6. Pay special attention to the alledged need, the alternatives and mitigation sections. Does the proposed mitigation really make the project or plan acceptable? Did you support another alternative in the scoping process which is not in the
7. Some additional questions to ask include: Has the no-action alternative been fully considered? Have the environmental impacts been dismissed or understated? Are there important data gaps? If so, has a worse-case analysis been presented
8. When you have finished reviewing and marking the DEIS, begin your written comments with a summary of your views. Was the DEIS adequate or inadequate? Is the alledged need justified? Were all feasible alternatives considered? Do you con
sider the environmental impacts acceptable? Is the mitigation proposed adequate?
9. The Agency is required to respond to all substanative comments. Your comments should clearly refer to specific sections of the DEIS. Use a consistent reference notation in your comments (e.g. Page 31, paragraph two) and address the point
s covered in items 4-7 above. Ask questions, request deletions, or propose actual changes or additions to the DEIS. Comments that merely object to something will usually receive a Comment noted. response.
10. Request a copy of the Final EIS and the Agency's decision docuement. Get your comments in on time.
In summary, while an EIS is supposed to be a factual and unbiased analysis of agency actions, it often serves as a measure of political support for or against a project. The more citizens that can provide comments the better.
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