Five years' experience with NEPA has taught environmentalists many lessons, but one of the most important is the necessity for effective administrative procedures for providing early public notice of proposed governmental actions that might significantly affect the environment.

While the Council on Environmental Quality's 1971 guidelines¹ implementing NEPA's impact statement provisions acknowledged that federal agencies "have a responsibility to develop procedures to insure the fullest practicable provision of timely public information and understanding of Federal plans and programs with environmental impact," they did little to assure that agencies would shoulder this burden. Under these guidelines, the agency that prepared an environmental impact statement was responsible for making the statement and any comments received concerning it available to the public pursuant to the public information section of the Freedom of Information Act.² But given the provisions of that statute, this represented essentially a duty to make information available upon request rather than to take the initiative and notify the public of the preparation or completion of impact statements and of their availability. The only requirement in the guidelines for publication in the Federal Register concerned notice and summaries of EPA comments on proposed federal action pursuant to EPA's substantive review authority under §309 of the Clean Air Act Amendments of 1970.³