Federal Environmental Impact Statements: Overly Inflated Needs Result in NeedlessEnvironmental Harm

Document Type


Journal/Book Title/Conference

Electronic Green Journal



Publication Date

Spring 4-1-2006


According to federal regulations, an Environmental Impact Statement (EIS) must include a statement of the purpose of, and need for, the proposed action. Unfortunately, the regulations do not specify how to determine the need. Typically, the declared need for a proposed action includes items that are not genuine needs. They are necessary conditions for achieving goals that are merely desired. The result of such overly inflated needs is, literally, needless environmental harm. The author presents criteria for identifying needs that have been developed by philosophers David Braybrooke and Garrett Thomson. These criteria are useful for gauging how far federal agencies are from a defensible conception of need. The author develops a principle that federal agencies should follow as they formulate the need for a proposed action in an EIS. If adopted, this principle would help eliminate overly inflated needs for proposed actions, leading to more environmentally sensitive decisions.

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