What does NEPA expect of Federal Agencies with respect to indirect and cumulative impacts in the NEPA process?
The NEPA legislation itself does not mention indirect or cumulative impacts. The CEQ regulations address Federal agency responsibility applicable to indirect and cumulative impacts considerations, analysis, and documentation. We find reference to these impacts and requirements in the definition of the scope of a proposal (40 CFR § 1508.25) and in the content requirements for the environmental consequences section of an environmental impact statement (EIS) (40 CFR § 1502.16). The scope of an action (40 CFR §§ 1500.4, 1501.1, 1501.7, and 1508.25) consists of the range of actions (connected or closely related, cumulative, and similar actions), alternatives (no action, other reasonable alternatives, and mitigation measures), and impacts (direct, indirect and cumulative impacts) to be considered in an EIS. For the study to be meaningful the project scope must not be too broadly or too narrowly defined, nor should it be focused on every issue that can be imagined but will likely have little
