I. Is There a Problem?

National Environmental Policy Act (NEPA) environmental documents have gotten a reputation for poor quality of late, and there is general consensus that this reputation is largely deserved. The public, agencies, and NEPA practitioners agree that most documents are difficult to understand and hard to use. Here is some of the evidence:

In a survey conducted jointly by the American Association of State Highway and Transportation Officials (AASHTO) and the American Council of Engineering Companies (ACEC), 78% of respondents said there was a problem with the overall quality of environmental documents. Common problems cited included excessive length, disjointed organization, failure to reach conclusions, and poor writing.

In another study, the Council on Environmental Quality (CEQ) reported on NEPA's achievements and problems after a quarter century. The report found that "[w]hat is often lacking in [environmental impact statements (EISs)] is not raw data, but meaning--i.e., a comparison of the potential impacts... expressed in clear, concise language. NEPA is about making choices, not endlessly collecting raw data." The report succinctly stated that "[m]ore rigor in the analysis does not mean more weight in the document." The 25-year report also cited clear evidence of how environmental documents grow longer year by year.