4 Tips for Writing a Concise National Environmental Policy Act Document
- posted in: Knowledge Center
National Environmental Policy Act (NEPA) was written in 1969, the intent was to provide a mechanism that:
- Provided decision-makers with environmental planning information.
- Offered the public a way to participate in the decision-making process.
The idea was to provide as concise of an answer as possible. Those writing the Act envisioned environmental assessments (EAs) that did not exceed 10 pages in length, and environmental impact statements (EIS) that were under 150 pages. Today, it is not uncommon for EAs to reach 500 pages and EIS to run into the thousands. How can NEPA consultants reach the primary objectives for informed decisions and public involvement, when documents become so large and cumbersome that they become nearly impossible to understand?
Here are some general guidelines to writing concise, focused and defensible NEPA documents that provide decision-makers with accurate information, and engage the public in the process.
First, be concise. Describe the proposed action as simply as possible. For most projects, a one-page description of the project should be sufficient to describe what is being done. Instead of supplementing that description with page after page of description, use pictures, maps, and drawings to provide a better understanding to the reader. In an age where graphic design, computer simulations, and accurate and updated imagery are all readily available, graphic images can replace multiple pages of text. Additionally, quality graphics can take a complex project and present it to the public in a relatable way. Pictures really are worth a thousand words.
Second, cite references. The National Environmental Policy Act document doesn’t need to be the “end all” resource analysis piece for the project. Instead, it should summarize and cite various resource studies that are applicable whenever possible. In this regard, summaries and conclusions can be presented in a concise form, as long as they are well-supported with sufficient and defensible environmental planning research. In fact, using a broad variety of research to support impact determination makes a document more defensible in court, as cited research has not all been paid for by the proponent of the action. Citing a dozen references when reaching a conclusion in a one to two-page analysis is stronger than a 100-page discussion of your own processes.
Third, be direct. The entire premise of NEPA is disclosure, regardless of political or even social influence. If there are impacts, state them. If there are no impacts, state that. But state it simply, directly, and accurately. I’ve never seen an agency have problems with NEPA analysis that clearly stated impacts, but I’ve seen plenty of agencies have problems when they wanted to avoid stating impacts. As a NEPA professional, we are obligated to provide an accurate assessment of any impact. The decision maker and the public should not come away from the document wondering what the impacts may or may not be.
Lastly, value the public perspective in your analysis. NEPA documents can get very technical, very fast, and at times, that is necessary. But when writing an EA or EIS, keep in mind that the idea is to inform the public in a way that can be understood. We write these analysis documents to inform our friends, families, and neighbors about the impacts our decisions make. Hiding behind technical jargon and volumes of prose shows a lack of clear understanding.
A simply written, concise and well-supported National Environmental Policy Act document better serves the needs of busy decision makers and a concerned public. Keeping this at the forefront will not only allow NEPA consultants to elevate the profession, but better than that, will elevate the public trust and engagement in the process.