DOT Seeks Comment on Environmental Impact Document Length Limitations

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The U.S. Department of Transportation is seeking comment on its recent interim policy memos that require environmental impact statements for infrastructure projects to generally be limited to a maximum of 150 pages.

It also requires that the environmental assessment process be completed in two years and not exceed 75 pages, unless the projects are of an unusual scope or complexity.

“DOT anticipates that the page limits memorandum will improve the quality of environmental documentation while reducing the length of these documents,” DOT said in a Federal Register notice on Aug. 23.



The DOT memorandum documents discuss best practices to comply with page limits.

Federal Register DOT Page Limits by Transport Topics on Scribd

“DOT finds it necessary to issue this interim policy because lengthy National Environmental Policy Act documents, containing extraneous detail and needless data, have resulted in increases in both time and cost to complete the environmental review process,” the announcement said. It has also made it increasingly difficult for agency decision-makers and the public to find the relevant information regarding proposed actions.

“Setting appropriate page limits is recognized as a mechanism to reduce excessive paperwork and ensure that NEPA documentation is clear, concise and focused,” the announcement said.

DOT is seeking comments on the new interim policies — which are effective immediately — through Sept. 23.

The interim policy memos are in response to an August 2017 executive order and Council on Environmental Quality regulations requiring that NEPA documents “must concentrate on the issues that are truly significant to the action in question, rather than amassing needless detail.”

The president’s executive order also mandated that federal agencies use a “One Federal Decision” process for major infrastructure projects — those that require multiple authorizations by federal agencies.