Toward NEPA performance: A framework for assessing EIAs

Abstract

The National Environmental Policy Act (NEPA) provides a regulatory decision-making process that requires U.S. federal agencies to assess the purpose and socio-environmental impacts of a proposed action before deciding to move forward with that action. The multiplicity of NEPA objectives, the complex tradeoffs embedded in the Environmental Impact Assessment (EIA), and the difficulties in accessing data have presented challenges for evaluating NEPA performance. Researchers have responded with a growing array of performance dimensions and specialized measurement approaches. In this paper, we advance a performance framework for EIAs that integrates several of these dimensions and provides a conceptually coherent approach to procedural and substantive performance. The framework articulates three procedural elements (use of science and analysis, nature of public participation, and management of EIA processes); and three substantive elements (quality of both the NEPA review and action decision, and both the accountability and efficiency of the NEPA review decision). Each element is further elaborated by specific functions with specific variables as a basis for future performance measurements. We use two hypothetical use cases, drawn from public land management and federal highway planning, to illustrate how the performance concepts from the framework can be operationalized and measured.