The Council on Environmental Quality estimates that the federal agencies will spend $65 million annually to administer the National Environmental Policy Act when its provisions are fully operable.¹ After some initial agency attempts to delegate substantially all of the burden of impact statement preparation, the Greene County case² reversed the trend by stressing that the federal agencies themselves were primarily responsible for preparing the impact statement. This Comment suggests that, consistent with Greene County, a significant portion of the cost of preparation can be shifted to the nonfederal parties, without impairing the agencies' responsibility to undertake, on occasion, rather extensive field analyses for inclusion in the impact statement.

The mechanism for further shifting costs is the Independent Offices Appropriations Act of 1952, which confers authority on the federal agencies to charge parties for most, if not all, of the cost of impact statement preparation. The substantive burden of preparation, assessment, and analysis would not change; only the distribution of costs would. While preserving the duty of the agency itself to make the environmental assessment, the Act could aid in shifting the cost of compliance with NEPA to the direct beneficiaries of the "major federal action" that they have stimulated.