NATIONAL 

ENVIRONMENTAL 

POLICY ACT

Little Information 

Exists on NEPA 

Analyses 

Report to Congressional Requesters

April 2014

GAO-14-370

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-370, a report to 

congressional requesters

April 2014

NATIONAL ENVIRONMENTAL POLICY ACT: 

Little Information Exists On NEPA Analyses

Why GAO Did This Study

NEPA requires all federal agencies to 

evaluate the potential environmental 

effects of proposed projects—such as 

roads or bridges—on the human 

environment. Agencies prepare an EIS 

when a project will have a potentially 

significant impact on the environment. 

They may prepare an EA to determine 

whether a project will have a significant 

potential impact. If a project fits within 

a category of activities determined to 

have no significant impact—a CE—

then an EA or an EIS is generally not 

necessary. The adequacy of these 

analyses has been a focus of litigation.

GAO was asked to review various 

issues associated with completing 

NEPA analyses. This report describes

information on the (1) number and type 

of NEPA analyses, (2) costs and 

benefits of completing those analyses, 

and (3) frequency and outcomes of 

related litigation. GAO included 

available information on both costs and 

benefits to be consistent with standard 

economic principles for evaluating 

federal programs, and selected the 

Departments of Defense, Energy, the 

Interior, and Transportation, and the 

USDA Forest Service for analysis 

because they generally complete the 

most NEPA analyses. GAO reviewed 

documents and interviewed individuals

from federal agencies, academia, and 

professional groups with expertise in 

NEPA analyses and litigation. GAO’s

findings are not generalizeable to 

agencies other than those selected.

This report has no recommendations. 

GAO provided a draft to CEQ and 

agency officials for review and 

comment, and they generally agreed 

with GAO’s findings. 

What GAO Found

Governmentwide data on the number and type of most National Environmental 

Policy Act (NEPA) analyses are not readily available, as data collection efforts 

vary by agency. NEPA generally requires federal agencies to evaluate the 

potential environmental effects of actions they propose to carry out, fund, or 

approve (e.g., by permit) by preparing analyses of different comprehensiveness 

depending on the significance of a proposed project’s effects on the 

environment—from the most detailed Environmental Impact Statements (EIS) to 

the less comprehensive Environmental Assessments (EA) and Categorical 

Exclusions (CE). Agencies do not routinely track the number of EAs or CEs, but 

the Council on Environmental Quality (CEQ)—the entity within the Executive 

Office of the President that oversees NEPA implementation—estimates that 

about 95 percent of NEPA analyses are CEs, less than 5 percent are EAs, and 

less than 1 percent are EISs. Projects requiring an EIS are a small portion of all 

projects but are likely to be high-profile, complex, and expensive. The 

Environmental Protection Agency (EPA) maintains governmentwide information 

on EISs. A 2011 Congressional Research Service report noted that determining 

the total number of federal actions subject to NEPA is difficult, since most 

agencies track only the number of actions requiring an EIS.

Little information exists on the costs and benefits of completing NEPA analyses. 

Agencies do not routinely track the cost of completing NEPA analyses, and there 

is no governmentwide mechanism to do so, according to officials from CEQ, 

EPA, and other agencies GAO reviewed. However, the Department of Energy 

(DOE) tracks limited cost data associated with NEPA analyses. DOE officials told 

GAO that they track the money the agency pays to contractors to conduct NEPA 

analyses. According to DOE data, its median EIS contractor cost for calendar 

years 2003 through 2012 was $1.4 million. For context, a 2003 task force report 

to CEQ—the only available source of governmentwide cost estimates—

estimated that a typical EIS cost from $250,000 to $2 million. EAs and CEs 

generally cost less than EISs, according to CEQ and federal agencies.

Information on the benefits of completing NEPA analyses is largely qualitative.

According to studies and agency officials, some of the qualitative benefits of 

NEPA include its role in encouraging public participation and in discovering and 

addressing project design problems that could be more costly in the long run.

Complicating the determination of costs and benefits, agency activities under 

NEPA are hard to separate from other required environmental analyses under 

federal laws such as the Endangered Species Act and the Clean Water Act; 

executive orders; agency guidance; and state and local laws.

Some information is available on the frequency and outcome of NEPA litigation.

Agency data, interviews with agency officials, and available studies show that 

most NEPA analyses do not result in litigation, although the impact of litigation 

could be substantial if a single lawsuit affects numerous federal decisions or 

actions in several states. In 2011, the most recent data available, CEQ reported 

94 NEPA cases filed, down from the average of 129 cases filed per year from 

calendar year 2001 through calendar year 2008. The federal government prevails 

in most NEPA litigation, according to CEQ and legal studies. View GAO-14-370. For more information, 

contact Anne-Marie Fennell at (202) 512-3841 

or fennella@gao.gov.
Page i GAO-14-370 National Environmental Policy Act

Letter 1

Background 3

Data on the Number and Type of Most NEPA Analyses Are Not 

Readily Available 7

Little Information Exists on the Costs and Benefits of Completing 

NEPA Analyses 11

Some Information Is Available on the Frequency and Outcome of 

NEPA Litigation 19

Agency Comments and Our Evaluation 23

Appendix I Objectives, Scope, and Methodology 25

Appendix II Summary of Federal NEPA Data Collection Efforts 27

Appendix III CEQ NEPA Time Frame Guidelines 32

Appendix IV Sources of NEPA Litigation Data 33

Appendix V Comments from the Council on Environmental Quality 35

Appendix VI GAO Contacts and Staff Acknowledgments 37

Tables

Table 1: Number of Environmental Impact Statements from EPA, 

CEQ, and NAEP, 2008 through 2012 9

Table 2: Number of Environmental Impact Statements by Agency 

as Reported by National Association of Environmental 

Professionals (NAEP), 2008 through 2012 11

Contents
Page ii GAO-14-370 National Environmental Policy Act

Figure

Figure 1: Process for Implementing National Environmental Policy 

Act Requirements 5

Abbreviations

BLM Bureau of Land Management

CE Categorical Exclusion

CEQ Council on Environmental Quality

CRS Congressional Research Service

DOD Department of Defense

DOE Department of Energy

DOT Department of Transportation

eMNEPA electronic Management of NEPA

EA Environmental Assessment

EIS Environmental Impact Statement

EPA Environmental Protection Agency

FHWA Federal Highway Administration

NAEP National Association of Environmental Professionals

NEPA National Environmental Policy Act

PAPAI Project and Program Action Information 

PEPC Planning, Environment, and Public Comment

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Page 1 GAO-14-370 National Environmental Policy Act

441 G St. N.W.

Washington, DC 20548

April 15, 2014

The Honorable Peter DeFazio

Ranking Member

Committee on Natural Resources

House of Representatives

The Honorable Edward Markey

United States Senate

The National Environmental Policy Act (NEPA)—the statute requiring 

federal agencies to evaluate the potential environmental effects of 

proposed projects on the human environment—has been identified by 

critics as a cause of delay for projects because of time-consuming 

requirements and praised by proponents for, among other things, bringing 

public participation into government decision making.1 Under NEPA, all 

federal agencies generally are to evaluate the potential environmental 

effects of actions they propose to carry out, fund, or approve (e.g., by

permit)—including the development of infrastructure projects, such as 

roads and bridges. Enacted in 1970, NEPA, and the subsequent Council 

on Environmental Quality Regulations Implementing the Procedural 

Provisions of NEPA, set out an environmental review process that has 

two principal purposes: (1) to ensure that an agency carefully considers 

information concerning the potential environmental effects of proposed 

development projects and (2) to ensure that this information is made 

available to the public.2

 1

NEPA applies to federal agency policies, programs, plans, and projects (40 C.F.R. § 

1508.18(b)). The focus of this report is on development projects.

NEPA requires federal agencies to analyze the 

nature and extent of a project’s potential environmental effects and, in 

2

Pub. L. No. 91-190 (1970), codified at 42 U.S.C. § 4321-4347. NEPA’s congressional 

declaration of purpose states that the purposes of the act are “to declare a national policy 

which will encourage productive and enjoyable harmony between man and his 

environment; to promote efforts which will prevent or eliminate damage to the environment 

and biosphere and stimulate the health and welfare of man; to enrich the understanding of 

the ecological systems and natural resources important to the Nation; and to establish a 

Council on Environmental Quality.” 42 U.S.C. § 4321.
Page 2 GAO-14-370 National Environmental Policy Act

many cases, document these analyses.3

To respond to these objectives, we reviewed relevant publications, 

obtained documents and analyses from federal agencies, and interviewed 

federal officials and individuals from academia and professional 

associations with expertise in conducting NEPA analyses. Specifically, to 

describe the number and type of NEPA analyses from calendar year 2008 

through calendar year 2012 and what is known about the costs and 

benefits of NEPA analyses, we reported information identified through the 

literature review, interviews, and other sources. We selected the 

Departments of Defense, Energy, the Interior, and Transportation; and 

the Forest Service within the U.S. Department of Agriculture for analysis 

because they generally complete the most NEPA analyses. Our findings 

for these agencies are not generalizeable to other federal agencies but 

provide examples of NEPA implementation. To describe the frequency 

and outcome of NEPA litigation, we reviewed (1) laws, regulations, and 

agency guidance; (2) NEPA litigation data collected from federal entities 

and the National Association of Environmental Professionals (NAEP), the 

professional association for NEPA practitioners within and outside the 

federal government; and (3) relevant studies. To assess the reliability of 

data collected from the selected agencies, we reviewed existing 

documentation when available and interviewed officials, including those 

from the U.S. Department of Justice, knowledgeable about the data. We 

found all data to be sufficiently reliable for the purposes of this report. See 

The documentation and 

comprehensiveness of these analyses depends on the significance of a 

project’s potential effects on the environment. The adequacy of NEPA 

analyses has been a focus of litigation. You asked us to review various 

issues associated with completing NEPA analyses. This report describes 

information on the (1) number and type of NEPA analyses, (2) costs and 

benefits of completing those analyses, and (3) frequency and outcomes 

of related litigation. We included available information on both costs and 

benefits to be consistent with standard economic principles for evaluating 

federal programs and generally accepted government auditing standards.

 3

The CEQ “Regulations for Implementing the Procedural Provisions of the National 

Environmental Policy Act” (CEQ regulations), 40 C.F.R. Parts 1500-1508, set out the 

levels of analysis and documentation for complying with NEPA. The level of analysis and 

documentation can take the form of a Categorical Exclusion (CE), Environmental 

Assessment (EA), or Environmental Impact Statement (EIS). Not all CEs are documented 

at the time the CE is used for a specific proposed project.
Page 3 GAO-14-370 National Environmental Policy Act

appendix I for additional details on our objectives, scope, and 

methodology.

We conducted this performance audit from June 2013 to April 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Under NEPA, federal agencies generally are to evaluate the likely 

environmental effects of projects they are proposing by preparing either 

an Environmental Assessment (EA) or a more detailed Environmental 

Impact Statement (EIS), assuming no Categorical Exclusion (CE) applies. 

Agencies may prepare an EA to determine whether a proposed project is 

expected to have a potentially significant impact on the human 

environment.4 If prior to or during the development of an EA, the agency 

determines that the project may cause significant environmental impacts, 

an EIS should be prepared. However, if the agency, in its EA, determines 

there are no significant impacts from the proposed project or action, then 

it is to prepare a document—a Finding of No Significant Impact—that 

presents the reasons why the agency has concluded that no significant 

environmental impacts will occur if the project is implemented. An EIS is a 

more detailed statement than an EA, and NEPA implementing regulations 

specify requirements and procedures—such as providing the public with 

an opportunity to comment on the draft document—applicable to the EIS 

process that are not mandated for EAs.5

If a proposed project fits within a category of activities that an agency has 

already determined normally does not have the potential for significant 

 4

The human environment is interpreted comprehensively to include the natural and

physical environment and the relationship of people to that environment (40 C.F.R. § 

1508.14). The effects analyzed under NEPA include ecological, aesthetic, historic, 

cultural, economic, social, or health (40 C.F.R. § 1508.8).

5

An EIS must, among other things, (1) describe the environment that will be affected, (2) 

identify alternatives to the proposed action and identify the agency’s preferred alternative, 

(3) present the environmental impacts of the proposed action and alternatives, and (4) 

identify any adverse environmental impacts that cannot be avoided should the proposed 

action be implemented.

Background
Page 4 GAO-14-370 National Environmental Policy Act

environmental impacts—a CE—and the agency has established that 

category of activities in its NEPA implementing procedures, then it 

generally need not prepare an EA or EIS.6

 6

Some categorical exclusions are established by statute and therefore generally do not 

require an agency determination that such actions do not have a significant environmental 

impact.

The agency may instead 

approve projects that fit within the relevant category by using one of its 

established CEs. For example, the Bureau of Land Management (BLM) 

within the Department of the Interior (Interior) has CEs in place for 

numerous types of activities, such as constructing nesting platforms for 

wild birds and constructing snow fences for safety. For a project to be 

approved using a CE, the agency must determine whether any 

extraordinary circumstances exist in which a normally excluded action 

may have a significant effect. Figure 1 illustrates the general process for 

implementing NEPA requirements.
Page 5 GAO-14-370 National Environmental Policy Act

Figure 1: Process for Implementing National Environmental Policy Act 

Requirements

Private individuals or companies may become involved in the NEPA 

process when a project they are developing needs a permit or other 

authorization from a federal agency to proceed, such as when the project 

involves federal land. For example, a company may apply for such a 

permit in constructing a pipeline crossing federal lands; in that case, the 

agency that is being asked to issue the permit must evaluate the potential 

environmental effects of constructing the pipeline under NEPA. The 

private company or developer may in some cases provide environmental 

analyses and documentation or enter into an agreement with an agency 

to pay a contractor for the preparation of environmental analyses and 
Page 6 GAO-14-370 National Environmental Policy Act

documents, but the agency remains ultimately responsible for the scope 

and content of the analyses under NEPA.7

The Council on Environmental Quality (CEQ) within the Executive Office 

of the President oversees the implementation of NEPA, reviews and 

approves federal agency NEPA procedures, and issues regulations and 

guidance documents that govern and guide federal agencies’

interpretation and implementation of NEPA.8 The Environmental 

Protection Agency (EPA) also plays two key roles in other agencies’

NEPA processes. First, EPA reviews and publicly comments on the 

adequacy of each draft EIS and the environmental impacts of the 

proposed actions reviewed in the EIS. If EPA determines that the action is 

environmentally unsatisfactory, it is required by law to refer the matter to 

CEQ. Second, EPA maintains a national EIS filing system. Federal 

entities must publish in the Federal Register a Notice of Intent to prepare 

an EIS and file their draft and final EISs with EPA, which publishes 

weekly notices in the Federal Register listing EISs available for public 

review and comment.9

CEQ’s regulations implementing NEPA require federal agencies to solicit 

public comment on draft EISs.10

 7

40 C.F.R. § 1506.5.

When the public comment period is 

finished, the agency proposing to carry out or permitting a project is to 

analyze comments, conduct further analysis as necessary, and prepare 

the final EIS. In the final EIS, the agency is to respond to the substantive 

comments received from other government agencies and the public. 

Sometimes a federal agency must prepare a supplemental analysis to 

either a draft or final EIS if it makes substantial changes in the proposed 

action that are relevant to environmental concerns, or if there are 

significant new circumstances or information relevant to environmental 

8

40 C.F.R. Parts 1500-1508.

9

The EIS process begins with publication of a Notice of Intent stating an agency intends to 

prepare an EIS for a proposed project. EPA publishes Notices of Availability in the Federal 

Register notifying the public when a draft EIS is available for comment and when a final 

EIS is has been issued.

10While there is no corresponding requirement for an EA public comment period, agencies 

may provide one. See, e.g., 40 C.F.R. § 1506.6 (Agencies shall make “diligent efforts to 

involve the public in preparing and implementing their NEPA procedures.”)
Page 7 GAO-14-370 National Environmental Policy Act

concerns.11 Further, in certain circumstances, agencies may—through 

“incorporation by reference,” “adoption,” or “tiering”—use another analysis 

to meet some or, in the case of adoption, all of the environmental review 

requirements of NEPA.12

Unlike other environmental statutes, such as the Clean Water Act or the 

Clean Air Act, no individual agency has enforcement authority with regard 

to NEPA’s implementation.13 This absence of enforcement authority is 

sometimes cited as the reason that litigation has been chosen as an 

avenue by individuals and groups that disagree with how an agency 

meets NEPA requirements for a given project.14 For example, a group 

may allege that an EIS is inadequate, or that the environmental impacts 

of an action will in fact be significant when an agency has determined 

they are not. Critics of NEPA have stated that those who disapprove of a 

federal project will use NEPA as the basis for litigation to delay or halt that 

project. Others argue that litigation only results when agencies do not 

comply with NEPA’s procedural requirements.

Governmentwide data on the number and type of most NEPA analyses 

are not readily available, as data collection efforts vary by agency (see 

app. II for a summary of federal NEPA data collection efforts). Agencies 

do not routinely track the number of EAs or CEs, but CEQ estimates that 

EAs and CEs comprise most NEPA analyses. EPA publishes and 

maintains governmentwide information on EISs.

 1140 CFR § 1502.9(c)(1).

12See 40 C.F.R. §§ 1500.4, 1500.5, and regulations cited therein.

13Also, unlike these other laws, while NEPA imposes procedural requirements, it does not 

establish substantive standards.

14CRS, The National Environmental Policy Act (NEPA): Background and Implementation, 

RL33152 (Washington, D.C.: Jan. 10, 2011). NEPA does not contain civil or criminal 

enforcement provisions; litigation challenging an agency’s compliance is brought under 

the Administrative Procedure Act.

Data on the Number 

and Type of Most 

NEPA Analyses Are 

Not Readily Available
Page 8 GAO-14-370 National Environmental Policy Act

Many agencies do not routinely track the number of EAs or CEs. 

However, based on information provided to CEQ by federal agencies, 

CEQ estimates that about 95 percent of NEPA analyses are CEs, less 

than 5 percent are EAs, and less than 1 percent are EISs. These 

estimates were consistent with the information collected on projects 

funded by the American Recovery and Reinvestment Act of 2009 

(Recovery Act).15 Projects requiring an EIS are a small portion of all 

projects but are likely to be high-profile, complex, and expensive. As the 

Congressional Research Service (CRS) noted in its 2011 report on 

NEPA, determining the total number of federal actions subject to NEPA is 

difficult, since most agencies track only the number of actions requiring 

an EIS.16

The percentages of EISs, EAs, and CEs vary by agency because of 

differences in project type and agency mission. For example, the 

Department of Energy (DOE) reported that 95 percent of its 9,060 NEPA 

analyses from fiscal year 2008 to fiscal year 2012 were CEs, 2.6 percent 

were EAs, and 2.4 percent were EISs or supplement analyses. Further, in 

June 2012, we reported that the vast majority of highway projects are 

processed as CEs, noting that the Federal Highway Administration 

(FHWA) within the Department of Transportation (DOT) estimated that 

approximately 96 percent of highway projects were processed as CEs, 

based on data collected in 2009.17

Of the agencies we reviewed, DOE and the Forest Service officials told 

us that CEs are likely underrepresented in their totals because agency 

Representing the lowest proportion of 

CEs in the data available to us, the Forest Service reported that 78 

percent of its 14,574 NEPA analyses from fiscal year 2008 to fiscal year 

2012 were CEs, 20 percent were EAs, and 2 percent were EISs.

 15The Recovery Act required the President to report to the Senate Environment and Public 

Works Committee and the House Natural Resources Committee every 90 days until 

September 30, 2011 on the status and progress of projects and activities funded by this 

Act with respect to compliance with National Environmental Policy Act requirements and 

documentation. Pub. L. No. 111-5, § 1609(c), 123 Stat. 304 (2009). Recovery Act projects 

may not be representative of ratios for all NEPA analyses. CEQ reports to Congress on 

the status and progress of NEPA reviews under the Recovery Act can be accessed here.

16CRS, The National Environmental Policy Act (NEPA): Background and Implementation, 

RL33152 (Washington, D.C.: Jan. 10, 2011).

17GAO, Highway Projects: Some Federal and State Practices to Expedite Completion 

Show Progress, GAO-12-593 (Washington, D.C.: June 6, 2012).

Many Agencies Do Not 

Routinely Track the 

Number of EAs or CEs, 

but CEQ Estimates That 

EAs and CEs Comprise 

Most NEPA Analyses
Page 9 GAO-14-370 National Environmental Policy Act

systems do not track certain categories of CEs considered “routine”

activities, such as emergency preparedness planning. For example, DOE 

officials stated that the department has two types of CEs, those that (1) 

are routine (e.g., administrative, financial, and personnel actions;

information gathering, analysis, and dissemination) and are not tracked 

and (2) are documented as required by DOE regulations.

EPA publishes and maintains governmentwide information on EISs, 

updated when Notices of Availability for draft and final EISs are published 

in the Federal Register. CEQ and NAEP publish publicly available reports 

on EISs using EPA data.18

Table 1: Number of Environmental Impact Statements from EPA, CEQ, and NAEP, 2008 through 2012

As shown in table 1, the three compilations of 

EIS data produce different totals.

Environmental Protection 

Agency (EPA)

Council on Environmental 

Quality (CEQ)

National Association of 

Environmental Professionals 

(NAEP)

Calendar year Draft Final Total Draft Final Total Draft Final Total

2008 270 277 547 270 277 547a 272 276 548b

2009 252 203 455 252 203 455c 277 222 499

2010 242 240 482 241 246 487 243 231 474

2011 235 201 436 234 201 435 234 204 438

2012 200 197 397 199 198 397 194 210 404

Total 1,199 1,118 2,317 1,196 1,125 2,321 1,220 1,143 2,363

Sources: GAO analysis of EPA data, and CEQ and NAEP reports.

Notes:

NEPA calls for federal agencies to circulate a draft Environmental Impact Statement (EIS) for public 

review and comment. When the public comment period is finished, the agency analyzes comments, 

conducts further analysis as necessary, and prepares the final EIS. The final EIS is circulated for 

review and may be made available for public review and comment.

The differences in EIS numbers are likely due to different assumptions used to count the number of 

EISs and minor inconsistencies in the EPA data compiled for the CEQ and NAEP reports and GAO’s 

 18NAEP’s annual NEPA reports generally include two sets of EIS data. The first set, 

presented in tables 1 and 2, reflects NAEP’s analysis of the number of draft and final EIS 

announcements published in the Federal Register. The second set of EIS data are used 

by NAEP to analyze the time frames associated with completing EISs. The two sets of EIS 

data within NAEP reports generally do not match, in part because the sample of EISs 

used to evaluate time frames excludes certain projects, such as “adoptions” or EISs that 

were subsequently supplemented.

Governmentwide Data Are 

Available on EISs
Page 10 GAO-14-370 National Environmental Policy Act

analysis of EPA’s database. EPA officials told us that the data it provides to others may differ

because EPA periodically corrects the manually entered data in their EIS database.

a

In 2008, two different CEQ documents listed 543 and 547 total EISs, respectively. We used the 547 

value in this table because it matched the sum of the draft and final EIS reported by CEQ in 2008 and 

also because it matched the total number we derived from the information supplied by EPA.

b

One section of NAEP’s Annual NEPA Report 2008 identified a total of 548 EISs for 2008, while 

another section of the report identified a total of 547. We use 548 for this table to remain consistent 

with NAEP’s summary of EIS data for 2008.

c

For 2009, the CEQ source document shows 450 for the total number of EISs, but this is a 

computation error because the total from adding the “draft” and “final” entries is 455.

According to CEQ and EPA officials, the differences in EIS numbers 

shown in table 1 are likely due to different assumptions used to count the 

number of EISs and minor inconsistencies in the EPA data compiled for 

the CEQ and NAEP reports and for our analysis of EPA’s data. CEQ 

obtains the EIS data it reports based on summary totals provided by EPA. 

Occasionally, CEQ also gathers some CE, EA, and EIS data through its 

“data call” process, by which it aggregates information submitted by 

agencies that use different data collection mechanisms of varying quality. 

According to a January 2011 CRS report on NEPA, agencies track the 

total draft, final, and supplemental EISs filed, not the total number of 

individual federal actions requiring an EIS.19

Four agencies—the Forest Service, BLM, FHWA, and the U.S. Army 

Corps of Engineers within the Department of Defense (DOD)—are 

generally the most frequent producers of EISs, accounting for 60 percent 

of the EISs in 2012, according to data in NAEP’s April 2013 report.

In other words, agency data 

generally reflect the number of EIS documents associated with a project, 

not the number of projects.

20 As 

shown in table 2, these agencies account for over half of total draft and 

final EISs from 2008 through 2012, according to NAEP data.

 19CRS, The National Environmental Policy Act (NEPA): Background and Implementation, 

RL33152 (Washington, D.C.: Jan. 10, 2011).

20NAEP, Annual NEPA Report 2012 of the National Environmental Policy Act (NEPA) 

Practice (April 2013).
Page 11 GAO-14-370 National Environmental Policy Act

Table 2: Number of Environmental Impact Statements by Agency as Reported by National Association of Environmental 

Professionals (NAEP), 2008 through 2012

Forest Service

Bureau of Land 

Managementa

Federal Highway 

Administration

Army Corps of 

Engineers All other agenciesb

Calendar 

year Number

Percentage 

of total Number

Percentage 

of total Number

Percentage 

of total Number

Percentage 

of total Number

Percentage 

of total Total

2008 123 22 49 9 65 12 43 8 268 49 548c

2009 134 27 28 6 58 12 41 8 238 48 499

2010 104 22 55 12 56 12 39 8 220 46 474

2011 109 25 42 10 49 11 33 8 205 47 438

2012 102 25 56 14 44 11 41 10 161 40 404

Total 572 24 230 10 272 12 197 8 1,092 46 2,363

Source: GAO analysis of NAEP data.

Note: The National Environmental Policy Act (NEPA) calls for federal agencies to solicit input by 

submitting a draft Environmental Impact Statement (EIS) for public comment. When the public 

comment period is finished, the agency analyzes comments, conducts further analysis as necessary, 

and prepares the final EIS.

a

According to BLM officials, BLM completed 53 NEPA analyses in 2010, 44 in 2011, and 20 in 2012. 

We present NAEP’s analysis of EPA data in this table.

b

In 2012, 31 other agencies completed at least 1 draft or final EIS. Five of them prepared 10 or more, 

including the National Park Service (21 draft and final EISs) and the Fish and Wildlife Service (19), 

both within the Department of the Interior; the National Oceanic and Atmospheric Administration 

within the Department of Commerce (17); the Navy within the Department of Defense (14); and the 

Federal Transit Administration within the Department of Transportation (10). The list of agencies

varied somewhat for each of the other fiscal years presented (2008 through 2011).

c

One section of NAEP’s Annual NEPA Report 2008 identified a total of 548 EISs for 2008, while 

another section of the report identified a total of 547. We use 548 for this table to remain consistent 

with NAEP’s summary of EIS data for 2008.

Little information exists at the agencies we reviewed on the costs and 

benefits of completing NEPA analyses. We found that, with few 

exceptions, the agencies did not routinely track data on the cost of 

completing NEPA analyses, and that the cost associated with conducting 

an EIS or EA can vary considerably, depending on the complexity and 

scope of the project. Information on the benefits of completing NEPA 

analyses is largely qualitative. Complicating matters, agency activities 

under NEPA are hard to separate from other environmental review tasks 

under federal laws, such as the Clean Water Act and the Endangered 

Species Act; executive orders; agency guidance; and state and local 

laws.

Little Information 

Exists on the Costs 

and Benefits of 

Completing NEPA 

Analyses
Page 12 GAO-14-370 National Environmental Policy Act

Little information exists on the cost of completing NEPA analyses. With 

few exceptions, the agencies we reviewed do not track the cost of 

completing NEPA analyses, although some of the agencies tracked 

information on NEPA time frames, which can be an element of project 

cost.

In general, we found that the agencies we reviewed do not routinely track 

data on the cost of completing NEPA analyses. According to CEQ 

officials, CEQ rarely collects data on projected or estimated costs related 

to complying with NEPA. EPA officials also told us that there is no 

governmentwide mechanism to track the costs of completing EISs. 

Similarly, most of the agencies we reviewed do not track NEPA cost data. 

For example, Forest Service officials said that tracking the cost of 

completing NEPA analyses is not currently a feature of their NEPA data 

collection system. Complicating efforts to record costs, applicants may, in 

some cases, provide environmental analyses and documentation or enter 

into an agreement with the agency to pay for the preparation of NEPA 

analyses and documentation needed for permits issued by federal 

agencies.21

Two NEPA-related studies completed by federal agencies illustrate how it 

is difficult to extract NEPA cost data from agency accounting systems. An 

August 2007 Forest Service report on competitive sourcing for NEPA 

compliance stated that it is “very difficult to track the actual cost of 

performing NEPA. Positions that perform NEPA-related activities are 

currently located within nearly every staff group, and are funded by a 

large number of budget line items. There is no single budget line item or 

budget object code to follow in attempting to calculate the costs of doing 

NEPA.”

Agencies generally do not report costs that are “paid by the 

applicant” because these costs reflect business transactions between 

applicants and their contractors and are not available to agency officials.

22

 21The agency remains responsible for the scope and content of the analyses under NEPA 

and the NEPA documentation. 40 C.F.R. § 1506.5.

Similarly, a 2003 study funded by FHWA evaluating the 

22U.S. Forest Service, Competitive Sourcing Program Office, Feasibility Study of Activities 

Related to National Environmental Policy Act (NEPA) Compliance (Washington, D.C.: 

Aug. 10, 2007).

Little Information Exists on 

the Cost of Completing 

NEPA Analyses

Most Agencies We Reviewed 

Do Not Track the Cost of 

Completing NEPA Analyses
Page 13 GAO-14-370 National Environmental Policy Act

performance of environmental “streamlining” noted that NEPA cost data 

would be difficult to segregate for analysis.23

However, DOE tracks limited cost data associated with NEPA analyses. 

DOE officials told us that they track the funds the agency pays to 

contractors to prepare NEPA analyses and does not track other costs, 

such as the time spent by DOE employees. According to DOE data, the 

average payment to a contractor to prepare an EIS from calendar year 

2003 through calendar year 2012 was $6.6 million, with the range being a 

low of $60,000 and a high of $85 million.24 DOE’s median EIS contractor 

cost was $1.4 million over that time period. More recently, DOE’s March 

2014 NEPA quarterly report stated that for the 12 months that ended 

December 31, 2013, the median cost for the preparation of four EISs for 

which cost data were available was $1.7 million, and the average cost 

was $2.9 million. For context, a 2003 task force report to CEQ—the only 

available source of governmentwide cost estimates—estimated that an 

EIS typically cost from $250,000 to $2 million.25

In comparison, DOE’s payments to contractors to produce an EA ranged 

from $3,000 to $1.2 million with a median cost of $65,000 from calendar 

year 2003 through calendar year 2012, according to DOE data. In its 

March 2014 NEPA quarterly report, DOE stated that, for the 12 months 

that ended December 31, 2013, the median cost for the preparation of 8 

EAs was $73,000, and the average cost was $301,000. For 

governmentwide context, the 2003 task force report to CEQ estimated 

 23U.S. Department of Transportation, Federal Highway Administration, Evaluating the 

Performance of Environmental Streamlining: Phase II (Washington, D.C.: 2003). We have 

ongoing work reviewing what is known about any duplication resulting from state and 

federal environmental impact review requirements for federal highway projects, as 

required by Section 1322 of the Moving Ahead for Progress in the 21st Century Act, Pub. 

L. No. 112-141, 126 Stat. 405, 553 (2012). We expect to issue a final report by the end of

October 2014.

24According to DOE, the cost for the $85 million Hanford Tank Closure and Waste 

Management EIS includes the costs for three major EISs—waste management, high-level 

waste tank closure, and disposition of a nuclear reactor—that were started separately and 

ultimately integrated into one document.

25 The NEPA Task Force Report to The Council on Environmental Quality, Modernizing 

NEPA Implementation. (September 2003).
Page 14 GAO-14-370 National Environmental Policy Act

that an EA typically costs from $5,000 to $200,000.26

Some governmentwide information is available on time frames for 

completing EISs—which can be one element of project cost—but few 

estimates exist for EAs and CEs because most agencies do not collect 

information on the number and type of NEPA analyses, and few 

guidelines exist on time frames for completing environmental analyses 

(see app. III for information on CEQ NEPA time frame guidelines). NAEP 

annually reports information on EIS time frames by analyzing information 

published by agencies in the Federal Register, with the Notice of Intent to 

complete an EIS as the “start” date, and the Notice of Availability for the 

final EIS as the “end” date.

Agencies provided 

no cost data on CEs but stated that the cost of a CE—which, in many 

cases, is for a “routine” activity, such as repainting a building—was 

generally much lower than the cost of an EA.

27 Our review did not identify other 

governmentwide sources of these data. Based on the information 

published in the Federal Register, NAEP reported in April 2013 that the 

197 final EISs in 2012 had an average preparation time of 1,675 days, or 

4.6 years—the highest average EIS preparation time the organization had 

recorded since 1997.28

 26 The NEPA Task Force Report to The Council on Environmental Quality, Modernizing 

NEPA Implementation. (September 2003). This report estimated that a “small” EA typically 

costs from $5,000 to $20,000 and a “large” EA costs from $50,000 to $200,000, but the 

report did not define “small” and “large.”

From 2000 through 2012, according to NAEP, the 

27According to CEQ officials, time frame data do not reflect certain nuances in the NEPA 

process. There could be a number of “non-NEPA” reasons for the “start,” “pause,” and 

“stop” of a project, such as waiting for funding or a non-federal permit, authorization, or 

other determination.

28NAEP, Annual NEPA Report 2012 of the National Environmental Policy Act (NEPA) 

Practice (April 2013). NAEP’s estimates are subject to sampling error and highlight the 

considerable variability in the time frames associated with EISs across the federal 

government. NAEP presented its time frame data along with margins of error at one 

standard deviation. NAEP’s NEPA average preparation time of 1,675 days had a one 

standard deviation confidence interval of plus or minus 1,247 days (plus or minus 3.4 

years). Also, the number of final EISs included in this sample—197—does not match the 

number of final EISs—210—presented for 2012 in table 1. NAEP’s annual reports use two 

different sources of information on NEPA analyses, one for its count of NEPA analysis, 

and another for analyzing time frames.

Some Information Is Available 

on NEPA Time Frames
Page 15 GAO-14-370 National Environmental Policy Act

total annual average governmentwide EIS preparation time increased at 

an average rate of 34.2 days per year.29

In addition, some agency officials told us that time frame measures for 

EISs may not account for up-front work that occurs before the Notice of 

Intent to produce an EIS—the “start” date typically used in EIS time frame 

calculations. DOT officials told us that the “start” date is unclear in some 

cases because of the large volume of project development and planning 

work that occurs before a Notice of Intent is issued. DOE officials made a 

similar point, noting that time frames are difficult to determine for many 

NEPA analyses because there is a large volume of up-front work that is 

not captured by standard time frame measures. According to technical 

comments from CEQ and federal agencies, to ensure consistency in its 

NEPA metrics, DOE measures EIS completion time from the date of 

publication of the Notice of Intent to the date of publication of the notice of 

availability of the final EIS. Further, according to a 2007 CRS report, a 

project may stop and restart for any number of reasons that are unrelated 

to NEPA or any other environmental requirement.30

Less governmentwide information is available on the completion time for 

EAs and CEs. According to DOE’s June 2013 quarterly NEPA report, for 

the 12 months that ended March 31, 2013, the average completion time 

for 16 EAs was 13 months (with a median of 11 months). For the past 10 

calendar years (i.e., 2003 through 2012), DOE’s average EA completion 

time was 13 months (with a median of 9 months). Interior’s Office of 

Surface Mining estimated that its EAs take approximately 4 months on 

average to complete, and the Forest Service reported that its 501 EAs in 

fiscal year 2012 took an average of about 18 months to complete. 

Further, officials from Bureau of Indian Affairs within Interior told us that 

For example, a 10-

year time frame to complete a project may have been associated with 

funding issues, engineering requirements, changes in agency priorities, 

delays in obtaining nonfederal approvals, or community opposition to the 

project, to name a few.

 29For more information on EIS time frames, see Piet deWitt and Carole A. deWitt, “How 

Long Does It Take to Prepare an Environmental Impact Statement?” Environmental 

Practice 10, no. 4 (December 2008) and Piet deWitt and Carole A. deWitt, “Preparation 

Times for Final Environmental Impact Statements Made Available from 2007 through 

2010,” Environmental Practice 15, no. 2 (June 2013).

30CRS, The National Environmental Policy Act: Streamlining NEPA, RL33267 

(Washington, D.C.: Dec. 6, 2007).
Page 16 GAO-14-370 National Environmental Policy Act

their EAs are generally completed in about 1 month but that they may 

take up to 6 months depending on their complexity. In addition, DOT 

officials said that determining the start time of EAs and CEs is even more 

difficult than for EISs. The time for completing these can depend in large 

part on how much of the up-front work was done already as part of the 

preliminary engineering process and how many other environmental 

processes are involved (e.g., consultations under the Endangered 

Species Act).

The little governmentwide information that is available on CEs shows that 

they generally take less time to complete than EAs. DOE does not track 

completion times for CEs, but agency officials stated that they usually 

take 1 or 2 days. Similarly, officials at Interior’s Office of Surface Mining 

reported that CEs take approximately 2 days to complete. In contrast, 

Forest Service took an average of 177 days to complete CEs in fiscal 

year 2012, shorter than its average of 565 days for EAs, according to 

agency documents. The Forest Service documents its CEs with Decision 

Memos, which are completed after all necessary consultations, reviews, 

and other determinations associated with a decision to implement a 

particular proposed project are completed.

According to agency officials, information on the benefits of completing 

NEPA analyses is largely qualitative. We have previously reported that 

assessing the benefits of federal environmental requirements, including 

those associated with NEPA, is difficult because the monetization of 

environmental benefits often requires making subjective decisions on key 

assumptions.31

Encouraging public participation. NEPA is intended to help government 

make informed decisions, encourage the public to participate in those 

decisions, and make the government accountable for its decisions. Public

According to studies and agency officials, some of the

qualitative benefits of NEPA include its role as a tool for encouraging 

transparency and public participation and in discovering and addressing 

the potential effects of a proposal in the early design stages to avoid 

problems that could end up taking more time and being more costly in the 

long run.

 31GAO, Federal-Aid Highways: Federal Requirements for Highways May Influence 

Funding Decisions and Create Challenges, but Benefits and Costs Are Not Tracked, 

GAO-09-36 (Washington, D.C.: December 12, 2008).

Information on the 

Benefits of Completing 

NEPA Analyses Is Largely 

Qualitative
Page 17 GAO-14-370 National Environmental Policy Act

participation is a central part of the NEPA process, allowing agencies to 

obtain input directly from those individuals who may be affected by a 

federal action. DOE officials referred to this public comment component of 

NEPA as a piece of “good government architecture,” and DOD officials 

similarly described NEPA as a forum for resolving organizational 

differences by promoting interaction between interested parties inside and 

outside the government. Likewise, the National Park Service within 

Interior uses its Planning, Environment, and Public Comment (PEPC) 

system as a comprehensive information and public comment site for 

National Park Service projects, including those requiring NEPA 

analyses.32

Discovering and addressing design problems. One benefit of the 

environmental review process, according to a 2012 CRS report, is that it 

ultimately saves time and reduces overall project costs by identifying and 

avoiding problems that may occur in later stages of project 

development.33

 32Click 

Projects that make it through the NEPA process are 

financially and environmentally improved, according to a senior NAEP 

official, because the process helps planners avoid the multiyear cost of 

mitigating a project’s potential adverse effects up front by identifying and 

evaluating alternatives that would not otherwise have been identified. 

Moreover, agency officials who oversee federal NEPA programs told us 

that one of the benefits of NEPA analyses is that they lead to improved 

projects. For example, DOT officials stated that the NEPA process allows 

project decision makers to discover and solve design problems that could 

end up being more costly in the long run. Similarly, Forest Service 

officials said that NEPA leads to better decisions on projects because of 

the environmental information considered in the process. Providing 

examples to illustrate these points, CEQ published a document describing 

time savings and improved outcomes on projects funded by the Recovery 

Act. Similarly, NEPA Success Stories: Celebrating Forty Years of 

Transparency and Open Government—published in August 2010 as a 

joint effort by the Environmental Law Institute, the Grand Canyon Trust, 

and the Partnership Project—described and highlighted improved 

here for more information on PEPC.

33CRS, The Role of the Environmental Review Process in Federally Funded Highway 

Projects: Background and Issues for Congress, R42479, (Washington, D.C.: Apr. 11, 

2012).
Page 18 GAO-14-370 National Environmental Policy Act

environmental outcomes brought about through the NEPA process.34

DOE has also published a document showing its NEPA “success 

stories.”35 In one example from this document, DOE cited the November 

28, 2008, Final Programmatic EIS for the Designation of Energy Corridors 

on Federal Lands in 11 Western States (DOE/EIS-0386), that it had 

developed in cooperation with BLM. In this case, public comments 

resulted in the consideration of alternative routes and operating 

procedures for energy transmission corridors to avoid sensitive 

environmental resources.

Agency activities under NEPA are hard to separate from other required 

environmental analyses, further complicating the determination of costs 

and benefits. CEQ’s NEPA regulations specify that, to the fullest extent 

possible, agencies must prepare NEPA analyses concurrently with other 

environmental requirements. CEQ’s March 6, 2012, memorandum on 

Improving the Process for Preparing Efficient and Timely Environmental 

Reviews under the National Environmental Policy Act states that 

agencies “must integrate, to the fullest extent possible, their draft EIS with 

environmental impact analyses and related surveys and studies required 

by other statutes or executive orders, amplifying the requirement in the 

CEQ regulations.36

 34Click 

The goal should be to conduct concurrent rather than 

sequential processes whenever appropriate.” Different types of 

environmental analyses may also be conducted in response to other 

requirements under federal laws such as the Clean Water Act and the 

Endangered Species Act; executive orders; agency guidance; and state 

and local laws. As reported in 2011 by CRS, NEPA functions as an 

“umbrella” statute; any study, review, or consultation required by any 

here to see “NEPA Success Stories and Benefits.” As of February 26, 2014, CEQ’s 

NEPA.gov website was down due to security issues.

35DOE’s NEPA success stories can be found here.

3640 C.F.R. Parts 1500-1508, at § 1502.25.

Activities under NEPA Are 

Hard to Separate from 

Other Required 

Environmental Analyses, 

Complicating the 

Determination of Costs 

and Benefits
Page 19 GAO-14-370 National Environmental Policy Act

other law that is related to the environment should be conducted within 

the framework of the NEPA process.37

As a result, the biggest challenge in determining the costs and benefits of 

NEPA is separating activities under NEPA from activities under other 

environmental laws. According to DOT officials, the dollar costs for 

developing a NEPA analysis reported by agencies also includes costs for 

developing analyses required by a number of other federal laws, 

executive orders, and state and local laws, which potentially could be a 

significant part of the cost estimate. Similarly, DOD officials stated that 

NEPA is one piece of the larger environmental review process involving 

many environmental requirements associated with a project. As noted by 

officials from the Bureau of Reclamation within Interior, the NEPA process 

by design incorporates a multitude of other compliance issues and 

provides a framework and orderly process—akin to an assembly line—

which can help reduce delays. In some instances, a delay in NEPA is the 

result of a delay in an ancillary effort to comply with another law, 

according to these officials and a wide range of other sources.

Some information is available on the frequency and outcome of NEPA 

litigation. Agency data, interviews with agency officials, and available 

studies indicate that most NEPA analyses do not result in litigation, 

although the impact of litigation could be substantial if a lawsuit affects 

numerous federal decisions or actions in several states. The federal 

government prevails in most NEPA litigation, according to CEQ and 

NAEP data, and legal studies.

 37CRS, The National Environmental Policy Act (NEPA): Background and Implementation, 

RL33152 (Washington, D.C.: Jan. 10, 2011). According to technical comments from CEQ 

and federal agencies, this statement is overbroad. Studies, reviews, or consultations 

required by law and related to the environment may occur outside the NEPA process 

when necessary, and in fact this routinely occurs in real practice. Thus, according to the 

technical comments, it would be more accurate to track the language in the relevant CEQ 

regulation, 40 CFR 1500.2(c).

Some Information Is 

Available on the 

Frequency and 

Outcome of NEPA 

Litigation
Page 20 GAO-14-370 National Environmental Policy Act

Agency data, interviews with agency officials, and available studies 

indicate that most NEPA analyses do not result in litigation. While no 

governmentwide system exists to track NEPA litigation or its associated 

costs, NEPA litigation data are available from CEQ, the Department of 

Justice, and NAEP. Appendix IV describes how these sources gather 

information in different ways for different purposes.

The number of lawsuits filed under NEPA has generally remained stable 

following a decline after the early years of implementation, according to 

CEQ and other sources. NEPA litigation began to decline in the mid1970s and has remained relatively constant since the late 1980s, as 

reported by CRS in 2007.38 More specifically, 189 cases were filed in 

1974, according to the twenty-fifth anniversary report of CEQ. In 1994, 

106 NEPA lawsuits were filed. Since that time, according to CEQ data, 

the number of NEPA lawsuits filed annually has consistently been just 

above or below 100, with the exception of a period in the early- and mid2000s.39 In 2011, the most recent data available, CEQ reported 94 NEPA 

cases, down from the average of 129 cases filed per year from 2001 

through 2008.40

Although the number of NEPA lawsuits is relatively small when compared 

with the total number of NEPA analyses, one lawsuit can affect numerous 

federal decisions or actions in several states, having a far-reaching 

impact. In addition to CEQ regulations and an agency’s own regulations, 

according to a 2011 CRS report, preparers of NEPA analyses and 

documentation may be mindful of previous judicial interpretation in an 

In 2012, U.S. Courts of Appeals issued 28 decisions 

involving implementation of NEPA by federal agencies, according to 

NAEP data.

 38CRS, The National Environmental Policy Act: Streamlining NEPA, RL33267 

(Washington, D.C.: Dec. 6, 2007). 

39As summarized by CEQ on its website, since 2001, fewer than 175 NEPA cases were 

filed each year, with fewer than 100 filed each year in 2007, 2009, 2010, and 2011. A 

2004 report by the Environmental Law Institute cited an increase in the number of NEPA 

cases filed in 2001 and 2002. See Jay E. Austin, et al. Judging NEPA: A “Hard Look” at 

Judicial Decision Making Under the National Environmental Policy Act (Washington, D.C.: 

Environmental Law Institute, 2004).

40Steven K. Imig, NEPA Case Law Update, Rocky Mountain Mineral Law Foundation 

Special Institute on the National Environmental Policy Act, October 28-29, 2010, Paper 

12.

Available Data Show That 

Most NEPA Analyses Do 

Not Result in Litigation, 

but Individual Cases Can 

Have Substantial Impacts
Page 21 GAO-14-370 National Environmental Policy Act

attempt to prepare a “litigation-proof” EIS.41 CEQ has observed that such 

an effort may lead to an increase in the cost and time needed to complete 

NEPA analyses but not necessarily to an improvement in the quality of 

the documents ultimately produced.

The federal government prevails in most NEPA litigation, according to 

CEQ and NAEP data and other legal studies. CEQ annually publishes 

survey results on NEPA litigation that identify the number of cases 

involving a NEPA-based cause of action; federal agencies that were 

identified as a lead defendant; and general information on plaintiffs (i.e., 

grouped into categories, such as “public interest groups” and “business 

groups”); reasons for litigation; and outcomes of the cases decided during 

the year.42 In general, according to CEQ data, NEPA case outcomes are 

about evenly split between those involving challenges to EISs and those 

involving other challenges to the adequacy of NEPA analyses (e.g., EAs

and CEs). The federal government successfully defended its decisions in 

more than 50 percent of the cases from 2008 through 2011. For example, 

in 2011, 99 of the 146 total NEPA case dispositions—68 percent—

reported by CEQ resulted in a judgment favorable to the federal agency 

being sued or a dismissal of the case without settlement.43 In 2011, that 

rate increased to 80 percent if the 18 settlements reported by CEQ were 

considered successes.44

 41CRS, The National Environmental Policy Act (NEPA): Background and Implementation, 

RL33152 (Washington, D.C.: Jan. 10, 2011).

However, the CEQ data do not present enough 

case-specific details to determine whether the settlements should be 

considered as favorable dispositions. The plaintiffs, in most cases, were 

public interest groups.

42CEQ did not define the terms “public interest group” or “business group” in its published 

survey results. According to CEQ officials, CEQ used the terms “public interest group” to 

include citizen groups and environmental nongovernmental organizations and the term 

“business group” to include business, industry, and development focused groups and 

organizations.

43The total number of dispositions does not relate directly to the 94 cases filed in 2011 

because litigation may take multiple years to resolve and there may be more than one 

disposition per case.

44The CEQ surveys identify three types of nonadverse dispositions: (1) judgment for the 

defendant; (2) dismissal without settlement; and (3) settlement. 

The Federal Government 

Prevails in Most NEPA 

Litigation
Page 22 GAO-14-370 National Environmental Policy Act

Reporting litigation outcome data similar to CEQ’s, a January 2014 article 

on Forest Service land management litigation found that the Forest 

Service won nearly 54 percent of its cases and lost about 23 percent.

45

Other sources of information also show that the federal government 

prevails in most NEPA litigation. For example, NAEP’s 2012 annual 

NEPA report stated that the government prevailed in 24 of the 28 cases 

(86 percent) decided by U.S. Courts of Appeals. A NEPA legal treatise 

similarly reports that “government agencies almost always win their case 

when the adequacy of an EIS is challenged, if the environmental analysis 

is reasonably complete. Adequacy cases raise primarily factual issues on 

which the courts normally defer to the agency. The success record in 

litigation is more evenly divided when a NEPA case raises threshold 

questions that determine whether the agency has complied with the 

statute. An example is a challenge to an agency decision that an EIS was 

not required. Some lower federal courts are especially sensitive to agency 

attempts to avoid their NEPA responsibilities.”

About 23 percent of the cases were settled, which the study found to be 

an important dispute resolution tool. Litigants generally challenged 

logging projects, most frequently under the National Environmental Policy 

Act and the National Forest Management Act. The article found that the 

Forest Service had a lower success rate in cases where plaintiffs 

advocated for less resource use (generally initiated by environmental 

groups) compared to cases where greater resource use was advocated. 

The report noted that environmental groups suing the Forest Service for 

less resource use not only have more potential statutory bases for legal 

challenges available to them than groups seeking more use of national 

forest resources, but there are also more statutes that relate directly to 

enhancing public participation and protecting natural resources.

46 NAEP also provides 

detailed descriptions of cases decided by U.S. Courts of Appeals in its 

annual reports.47

 45Amanda M.A. Miner, Robert W. Mamsheimer, and Denise M. Keele, “Twenty Years of 

Forest Service Land Management Litigation,” Journal of Forestry 112, no. 1 (January 

2014).

46Daniel R. Mandelker, with the assistance of Robert L. Glicksman, Arianne Michalek 

Aughey, JD, and Donald McGillivray, NEPA Law and Litigation, 2nd ed. (Thomson 

Reuters/West, Rel. 10, 2012).

47NAEP, Annual NEPA Report 2012 of the National Environmental Policy Act (NEPA) 

Practice (April 2013).
Page 23 GAO-14-370 National Environmental Policy Act

We provided a draft of this product to the Council on Environmental 

Quality (CEQ) for governmentwide comments in coordination with the 

Departments of Agriculture, Defense, Energy, Interior, Justice, and 

Transportation, and the Environmental Protection Agency (EPA). In 

written comments, reproduced in appendix V, CEQ generally agreed with 

our findings. CEQ and federal agencies also provided technical 

comments that we incorporated, as appropriate.

We are sending copies of this report to the appropriate congressional 

committees; Chair of the Council on Environmental Quality; Secretaries of 

Defense, Energy, the Interior, and Transportation; Attorney General; 

Chief of the Forest Service within the Department of Agriculture; 

Administrator of EPA; and other interested parties. In addition, this report 

is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact us at (202) 512-3841 or fennella@gao.gov; or gomezj@gao.gov; 

and (202) 512-4523 or leporeb@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

Agency Comments 

and Our Evaluation
Page 24 GAO-14-370 National Environmental Policy Act

page of this report. GAO staff who made key contributions to this report 

are listed in appendix VI.

Anne-Marie Fennell

Director, Natural Resources and Environment

Alfredo Gomez

Director, Natural Resources and Environment

Brian Lepore

Director, Defense Capabilities and Management
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-14-370 National Environmental Policy Act

This appendix provides information on the scope of work and the 

methodology used to collect information on how we described the (1) 

number and type of National Environmental Policy Act (NEPA) analyses, 

(2) costs and benefits of completing those analyses, and (3) frequency 

and outcomes of related litigation. We included available information on 

both costs and benefits to be consistent with standard economic 

principles for evaluating federal programs and generally accepted 

government auditing standards.

To respond to these objectives, we reviewed relevant publications, 

obtained documents and analyses from federal agencies, and interviewed 

federal officials and individuals from academia and a professional 

association with expertise in conducting NEPA analyses. Specifically, to 

describe the number and type of NEPA analyses and what is known 

about the costs and benefits of NEPA analyses, we reported information 

identified through the literature review, interviews, and other sources. We 

selected the Departments of Defense, Energy, the Interior, and 

Transportation and the Forest Service within the U.S. Department of 

Agriculture for analysis because they generally complete the most NEPA 

analyses. Our findings for these agencies are not generalizeable to other 

federal agencies.

To assess the availability of information to respond to these objectives, 

we (1) conducted a literature search and review with the assistance of a 

technical librarian; (2) reviewed our past work on NEPA and studies from 

the Congressional Research Service; (3) obtained documents and 

analyses from federal agencies; and (4) interviewed officials who oversee 

federal NEPA programs from the Departments of Defense, Energy, the 

Interior, Justice, and Transportation; the Forest Service within the 

Department of Agriculture; the Environmental Protection Agency (EPA); 

the Council on Environmental Quality (CEQ) within the Executive Office of 

the President; and individuals with expertise from academia and the 

National Association of Environmental Professionals (NAEP)—a 

professional association representing private and government NEPA 

practitioners.

Specifically, to describe the number and type of NEPA analyses from 

calendar year 2008 through calendar year 2012, we analyzed data 

identified through the literature review and interviews. We focused on 

data and documents maintained by CEQ, EPA, and NAEP. CEQ and 

NAEP periodically report data on the number of certain types of NEPA 

analyses, and EPA maintains a database of Environmental Impact 

Statements, one of its roles in implementing NEPA. To generate 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-14-370 National Environmental Policy Act

information on the number of Environmental Impact Statements from 

EPA’s database, we sorted the data by calendar year and counted the 

number of analyses for each year. We did not conduct an extensive 

evaluation of this database, although a high-level analysis discovered 

potential inconsistencies. For example, EPA’s database contained entries 

with the same unique identifier, making it difficult to identify the exact 

number of NEPA analyses. We discussed these inconsistencies with EPA 

officials, who told us that they were aware of certain errors due to manual 

data entry and the use of different analysis methods. These officials said 

that EPA EIS data provided to others may differ because EPA periodically 

corrects the manually entered data. We did not count duplicate records in 

our analysis of EPA’s data. We believe these data are sufficiently reliable 

for the purposes of this report.

To describe what is known about the costs and benefits of NEPA 

analysis, we reported the available information on the subject identified 

through the literature review and interviews. To describe the frequency 

and outcome of NEPA litigation we (1) reviewed laws, regulations, and 

agency guidance; (2) reviewed NEPA litigation data generated by CEQ 

and NAEP; (3) interviewed Department of Justice officials; and (4) 

reviewed relevant legal studies.

Information from these sources is cited in footnotes throughout this report. 

To answer the various objectives, we relied on data from several sources. 

To assess the reliability of data collected by agencies and NAEP, we 

reviewed existing documentation, when available, and interviewed 

officials knowledgeable about the data. We found all data sufficiently 

reliable for the purposes of this report.

We conducted this performance audit from June 2013 to April 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Summary of Federal NEPA Data 

Collection Efforts

Page 27 GAO-14-370 National Environmental Policy Act

Federal National Environmental Policy Act (NEPA) data collection efforts 

vary by agency. The Council on Environmental Quality’s (CEQ) NEPA 

implementing regulations set forth requirements that federal agencies 

must adhere to, and require federal agencies to adopt their own 

procedures, as necessary, that conform with NEPA and CEQ’s 

regulations.1 Federal agencies decide how to apply CEQ regulations in 

the NEPA process. According to a 2007 Congressional Research Service 

(CRS) report, the CEQ regulations were meant to be generic in nature, 

with individual agencies formulating procedures applicable to their own 

projects.2

As stated by a CEQ official, “there is no master NEPA spreadsheet, and 

there are many gaps in NEPA-related data collected across the federal 

government.” To obtain information on agency NEPA activities, the official 

said that CEQ works closely with its federal agency NEPA contact group, 

composed of key officials responsible for implementing NEPA in each 

agency. CEQ meets regularly with these officials and uses this network to 

collect NEPA-related information through requests for information, 

whereby CEQ distributes a list of questions to relevant agencies and then 

collects and reports the answers. According to CEQ officials, NEPA data 

reported by CEQ are generated through these requests, which have 

quality assurance limitations because related activities at federal 

departments are themselves diffused throughout various offices.

The report states that this approach was taken because of the 

diverse nature of projects and environmental impacts managed by federal 

agencies with unique mandates and missions. Consequently, NEPA 

procedures vary to some extent from agency to agency, and 

comprehensive governmentwide data on NEPA analyses are generally 

not centrally collected.

Of the agencies we reviewed, the Departments of Defense, the Interior, 

and Transportation do not centrally collect information on NEPA analyses, 

allowing component agencies to collect the information, whereas the 

Department of Energy and the Forest Service within the Department of 

Agriculture aggregate certain data.

 1

40 C.F.R. § 1507.3.

2

CRS, The National Environmental Policy Act: Streamlining NEPA, RL33267 

(Washington, D.C.: Dec. 6, 2007).

Appendix II: Summary of Federal NEPA Data 

Collection Efforts
Appendix II: Summary of Federal NEPA Data 

Collection Efforts

Page 28 GAO-14-370 National Environmental Policy Act

Department of Defense (DOD). Each of the military services and defense 

agencies collects data on NEPA analyses, but DOD does not aggregate 

information that is collected on the number and type of NEPA analyses at 

the departmentwide level. Data collection within the military services and 

agencies is decentralized, according to DOD officials. For example, the 

Army collects Environmental Impact Statement (EIS) data at the 

Armywide level, and responsibility for Environmental Assessments (EA) 

and Categorical Exclusions (CE) are delegated to the lowest possible 

command level. DOD officials said that each of the services and defense 

agencies works to maintain a balance between the work that needs to be 

completed and the management effort needed to accomplish that work. 

While the level of information collected may vary by service or defense 

agency, each collects the information that it has determined necessary to 

manage its NEPA workload. According to these officials, every new 

information system and data call must generally come from existing 

funding, taking resources from other tasks.

Department of the Interior (Interior). Data are not collected at the 

department level, according to Interior officials, and Interior conducts its 

own departmentwide data calls to component bureaus and entities

whenever CEQ asks for NEPA-related information. The data collection 

efforts of its individual bureaus vary considerably. For example, the 

National Park Service uses its Planning, Environment, and Public 

Comment (PEPC) system as a comprehensive information and public 

comment site for National Park Service projects. Other Interior bureaus 

are beginning to track information or rely on less formal systems and not 

formalized databases. For example, the Bureau of Indian Affairs uses its 

internal NEPA Tracker system—started in September 2012—which the 

bureau states is to collect information on NEPA analyses to create a 

better administrative record to potentially identify new categories of CEs 

for future development and use. Prior to the NEPA Tracker system, the 

Bureau of Indian Affairs tracked NEPA analyses less formally, with 

varying information quality across the bureau’s different entities, 

according to agency officials. According to Bureau of Land Management 

officials, the bureau has developed and is currently implementing its 

ePlanning system, a comprehensive, bureau-wide, Internet-based tool for 

writing, reviewing, publishing, and receiving public commentary on land 

use plans and NEPA documents. The tool is fully operational, and the 

bureau expects to complete implementation in 2015. At the Bureau of 

Reclamation, NEPA activities are cataloged and tracked by each region 

or area office according to local procedures, and the information on the 

number and type of NEPA analyses resides with these offices. NEPA 
Appendix II: Summary of Federal NEPA Data 

Collection Efforts

Page 29 GAO-14-370 National Environmental Policy Act

information at the Fish and Wildlife Service, according to agency officials, 

is collected at the refuge level.

Department of Transportation (DOT). According to agency officials, each 

DOT administration—such as the Federal Highway Administration 

(FHWA), which funds highway projects; the Federal Motor Carrier Safety 

Administration, which develops commercial motor vehicle and driver 

regulations; and the Federal Aviation Administration, which is responsible 

for, among other things, the nation’s air traffic control system—has its 

own NEPA operating and data collection procedures that track NEPArelated information to varying degrees because each mode of 

transportation has different characteristics and needs.3 Environmental 

reviews for highway projects funded by FHWA have long been of interest 

to Congress and federal, state, and local stakeholders.4

Department of Energy (DOE). The Office of NEPA Policy and Compliance 

within DOE maintains a website where it posts extensive agencywide 

NEPA documentation, including information on the number and type of 

NEPA analyses completed since the mid-1990s and a series of quarterly 

lessons learned reports documenting certain NEPA performance metrics, 

including information on time and cost.

FHWA and its 52 

division offices have traditionally used an internal data system to track 

EIS documents. FHWA officials told us that they are in the process of 

replacing the agency’s legacy system with the new Project and Program 

Action Information (PAPAI) system, which went online in March 2013. 

PAPAI is capable of tracking information on EISs, EAs, and CEs,

including project completion time frames, but its use is not mandatory, 

according to DOT officials.

5 DOE’s September 2013 quarterly 

report documents available information on its NEPA analysis workload, 

completion times, and costs from 2003 through 2012.6

 3

According to technical comments from CEQ and federal agencies, several DOT 

administrations, including Federal Aviation Administration, are tracking the status of NEPA 

analyses, or NEPA status is reported as part of a larger financial tracking database.

DOE began 

tracking cost and completion time metrics in the mid-1990s because it 

4

GAO-12-593.

5

Click here to see the information on DOE’s website. 

6

DOE’s September 2013 quarterly report can be found here. These data are discussed in 

more detail elsewhere in this report.
Appendix II: Summary of Federal NEPA Data 

Collection Efforts

Page 30 GAO-14-370 National Environmental Policy Act

was concerned about the timeliness and cost of NEPA reviews.7

Department of Agriculture’s Forest Service. The Forest Service’s 

computer system, known as the Planning, Appeals, and Litigation 

System, provides information for responding to congressional requests for 

NEPA data, to support preparation for responding to lawsuits, and about 

overall project objectives and design. As stated by agency officials, data 

from the system can be used to identify trends in the preparation of NEPA 

analyses over time. This information can be valuable to managers in 

managing overall NEPA compliance and can identify innovative ways to 

deal with recurring environmental issues that affect projects, according to 

Forest Service officials. The system also provides tools to help the 

agency meet NEPA requirements, including automatic distribution of the 

schedule of proposed NEPA actions, a searchable database of draft 

EISs, and electronic filing of draft and final EISs to EPA.

DOE 

officials told us they collect these data because, in their view, “what gets 

measured gets done.” Making DOE NEPA analyses easily available 

allows others to apply the best practices and potentially avoid costly 

litigation, according to DOE officials.

CEQ also identified as a best practice the service’s electronic 

Management of NEPA (eMNEPA) pilot—a suite of web-based tools and 

databases to improve the efficiency of environmental reviews by enabling 

online submission and processing of public comments, among other 

things.8

 7

DOE, Secretarial Policy Statement on the National Environmental Policy Act, 

(Washington, D.C.: June 13, 1994). The secretarial policy statement is available 

On March 17, 2011, CEQ invited members of the public and 

federal agencies to nominate projects employing innovative approaches 

to complete environmental reviews more efficiently and effectively. On 

August 31, 2011, CEQ announced that eMNEPA was selected as part of 

the first NEPA pilot project. CEQ officials told us that they would prioritize 

the use of CEQ oversight resources to focus on identifying, 

disseminating, and encouraging agencies to use their additional 

resources in improving operational efficiency through tools like eMNEPA 

rather than focusing on improved data collection and reporting. 

Specifically, CEQ officials said that information technology tools that 

enable easy access to relevant technical information across the federal 

here.

8

More information on Forest Service’s eMNEPA is available here.
Appendix II: Summary of Federal NEPA Data 

Collection Efforts

Page 31 GAO-14-370 National Environmental Policy Act

government are also of value in enhancing the ability of agencies to 

conduct efficient and timely NEPA environmental reviews.
Appendix III: CEQ NEPA Time Frame 

Guidelines

Page 32 GAO-14-370 National Environmental Policy Act

The Council on Environmental Quality’s (CEQ) March 1981 guidance 

document published in the Federal Register titled Forty Most Asked 

Questions Concerning CEQ’s National Environmental Policy Act 

Regulations advises that

“. . . even large complex energy projects would require only about 12 months for the 

completion of the entire EIS process. For most major actions, this period is well within the 

planning time that is needed in any event, apart from NEPA. The time required for the 

preparation of program EISs may be greater. The Council also recognizes that some 

projects will entail difficult long-term planning and/or the acquisition of certain data which 

of necessity will require more time for the preparation of the EIS. Indeed, some proposals 

should be given more time for the thoughtful preparation of an EIS and development of a 

decision which fulfills NEPA’s substantive goals. For cases in which only an environmental 

assessment will be prepared, the NEPA process should take no more than 3 months, and 

in many cases substantially less, as part of the normal analysis and approval process for 

the action.”

1

CEQ’s National Environmental Policy Act (NEPA) regulations do not 

specify a required time frame for completing NEPA analyses. The 

regulations state that CEQ has decided that prescribed universal time 

limits for the entire NEPA process are too inflexible. The regulations also 

state that federal agencies are encouraged to set time limits appropriate 

to individual actions and should take into consideration factors such as 

the potential for environmental harm, size of the proposed action, and 

degree of public need for the proposed action, including the 

consequences of delay. CEQ’s March 6, 2012, memorandum on 

Improving the Process for Preparing Efficient and Timely Environmental 

Reviews under the National Environmental Policy Act encourages 

agencies to develop meaningful and expeditious timelines for 

environmental reviews, and it amplifies the factors an agency should take 

into account when setting time limits, noting that establishing appropriate 

and predictable time limits promotes the efficiency of the NEPA process. 

The CEQ regulations also require agencies to reduce delay by, among 

other things, integrating the NEPA process into early project planning, 

emphasizing interagency cooperation, integrating NEPA requirements 

with other environmental review requirements, and adopting 

environmental documents prepared by other federal agencies.

 1

CEQ, Memorandum to Agencies: Forty Most Asked Questions Concerning CEQ’s 

National Environmental Policy Act Regulations. 46 Fed. Reg. 18026 (Mar. 23, 1981) as 

amended.

Appendix III: CEQ NEPA Time Frame 

Guidelines
Appendix IV: Sources of NEPA Litigation Data

Page 33 GAO-14-370 National Environmental Policy Act

In general, there is no governmentwide system to track National 

Environmental Policy Act (NEPA) litigation and its associated costs. The 

Council on Environmental Quality (CEQ), the Department of Justice, and 

the National Association of Environmental Professionals (NAEP) gather 

NEPA litigation information in different ways for different purposes.

CEQ collects NEPA litigation data through periodic requests for 

information, whereby it distributes a list of questions to the general 

counsel offices of relevant agencies and then collects and reports the 

information on its website.1

The Department of Justice defends nearly all federal agencies when they 

face NEPA litigation.

CEQ’s NEPA litigation survey presents 

information on NEPA-based claims brought against agencies in court, 

including aggregated information on types of lawsuits and who brought 

the suits. The survey results do not present information on the cost of 

NEPA litigation because, according to officials from several of the 

agencies we reviewed, agencies do not track this information. For 

example, Forest Service officials told us that they do not centrally track 

the cost or time associated with the preparation for litigation. As another 

example, the Department of Energy’s litigation data do not include the 

cost of litigation or the time spent on litigation-related tasks, although it 

includes the number of NEPA-related cases over time.

2

 1

CEQ used to report on NEPA litigation in required annual reports, but the annual 

reporting requirement was eliminated by Congress, and the last annual report was issued 

in 1997. CEQ’s more recent NEPA litigation survey results are provided 

These officials told us that the department’s Case 

Management System database tracks limited information on NEPA cases 

handled by the Environment and Natural Resources Division, and the 

Executive Office for U.S. Attorneys case management system, called the 

Legal Information Office Network System, tracks NEPA cases at 

individual U.S. Attorneys’ Offices to some extent. However, Department 

of Justice officials told us that these systems do not interface with each 

other, so it would be impossible to gather comprehensive information on 

NEPA litigation from the Department of Justice.

here.

2

Such litigation is handled both by the Department of Justice’s Environment and Natural 

Resources Division and by individual U.S. Attorneys’ Offices depending upon the agency, 

the type of case, and the expertise of the department’s personnel. Agency personnel 

provide the Department of Justice with the administrative record that forms the basis of 

judicial review and provide assistance throughout the litigation process, as needed.

Appendix IV: Sources of NEPA Litigation 

Data
Appendix IV: Sources of NEPA Litigation Data

Page 34 GAO-14-370 National Environmental Policy Act

Further, Department of Justice officials told us that the department is not 

able to comprehensively identify all NEPA litigation because a single case 

could have numerous other environmental claims in addition to a single 

NEPA claim. In such instances, the Environment and Natural Resources 

Division’s Case Management System may not capture every claim raised 

in the case.3

The Department of Justice’s NEPA litigation data are not comparable to 

CEQ’s because the department’s system is designed to track cases, 

while CEQ provides information on NEPA events—such as the number of 

cases filed, number of injunctions or remands, and other decisions. There 

could be multiple NEPA events or decisions related to a single case. 

Department of Justice officials stated that they would not be able to 

reconcile CEQ’s information with information in Department of Justice 

systems.

As a result, the Department of Justice does not track trends 

in NEPA litigation or staff hours spent on NEPA cases. The cost of 

collecting the information would outweigh the management benefits of 

doing so, according to these officials.

NEPA litigation data collected by the third source—NAEP—differ from 

those collected by CEQ or the Department of Justice. NAEP collects 

information on NEPA cases decided by U.S. Courts of Appeals because 

these cases are generally the most significant to the NEPA practitioners 

that are NAEP’s members, according to NAEP officials. The NAEP report 

contains case study summaries of the latest developments in NEPA 

litigation to help NEPA practitioners understand how to account for new 

court-mandated requirements in NEPA analyses and does not attempt to 

track all NEPA litigation across the government.

 3

According to Department of Justice officials, the Environment and Natural Resources 

Division uses a customized Case Management System for internal purposes. This Case 

Management System includes case information such as the caption, lead statute, court 

district, case hours, and general outcomes. The Environment and Natural Resources 

Division generally uses the Case Management System information to measure 

performance, assess resource needs and expenditures, and track the hours of certain 

employees to individual cases.
Appendix V: Comments from the Council on 

Environmental Quality

Page 35 GAO-14-370 National Environmental Policy Act

Appendix V: Comments from the Council on 

Environmental Quality
Appendix V: Comments from the Council on 

Environmental Quality

Page 36 GAO-14-370 National Environmental Policy Act
Appendix VI: GAO Contacts and Staff 

Acknowledgments

Page 37 GAO-14-370 National Environmental Policy Act

Anne-Marie Fennell, (202) 512-3841 or fennella@gao.gov

Alfredo Gomez, (202) 512-3841 or gomezj@gao.gov

Brian Lepore, (202) 512-4523 or leporeb@gao.gov

In addition to the individuals named above, Anne Johnson and Harold 

Reich (Assistant Directors); Ronnie Bergman; Cindy Gilbert; Richard P. 

Johnson; Terence Lam; Alison O’Neill; Pepe Thompson; and John Wren 

made key contributions to this report.

Appendix VI: GAO Contacts and Staff 

Acknowledgments

GAO Contacts

Staff 

Acknowledgments

(361558)
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