Environmental Compliance

Programmatic v. Site-specific EIS's

To reduce excessive paperwork, the Council on Environmental Quality (CEQ) recommends (40 CFR • 1500.4) that agencies use program, policy, or plan environmental statements (broadly written environmental impact statements (EIS's)), and tier narrower documents to them so as to eliminate repetitive discussions of the same issues (40 CFR • 1500.4). An EIS of this type, which is often referred to in this Agency as a "programmatic EIS," allows the analysis, in a single document, of programs components which, if analyzed separately in site-specific EIS's, would require repetitive planning, analysis, or discussion. "Proposals which are related to each other closely enough to be, in effect, a single course of action shall be evaluated in a single impact statement."

" Agencies shall prepare statements on broad actions so that they are relevant to policy and are timed to coincide with meaningful points in agency planning and decisionmaking." When preparing statements on broad actions, agencies may find it useful to evaluate proposals in the following ways: geographically, generically, or by stage of technological development (40 CFR • 1502.4).

Site-specific statements (EIS's or environmental assessments (EA's)) prepared for actions of a narrow scope that are related to a broadly analyzed program should be tiered to the programmatic EIS. This eliminates unnecessary discussion of the same issues and allows the site-specific statement to focus only on new issues ripe for decisionmaking. The site-specific statement need only summarize the issues in the programmatic EIS and incorporate the programmatic EIS by reference (40 CFR • 1502.20). Not all major Federal actions are related to the actions of a broader program; such actions should be analyzed in a site-specific EIS which is not tiered to a programmatic EIS.

Programmatic EIS's prevent piecemealing (breaking up a broad action into its component parts, to present a perception of lower risk) by analyzing all related actions in a program simultaneously. Analyzing adverse environmental effects in a series of narrowly defined EIS's may result in failure to identify significant cumulative effects from the actions taken collectively. Programmatic EIS's tend to foster increased coordination between agencies, programs, and the public.