This is an open thread.
Most American energy usage is in heating too-large, separated houses and powering too-large, underutilized automobiles so folks never have to interact with anyone they don’t explicitly want to see.
But sure, instead of accepting the fundamental social changes that would easily stop the impending climate catastrophe, we refuse to give up the fantastical, impossible, unsustainable American Delusion of everyone owning a facsimile of a pastoral estate and buying a new car every 5 years to drive to a cushy, easy office job.
But sure, carbon concrete will save us.
The solution is both/and. Do everything we can get society to do, and hope things don’t get to bad. The urge toward isolated estates, too-large streets, and a disdain for city living goes back to the 1800s, and even earlier to Thomas Jefferson’s suspicion of cities and preachers calling cities dens of sin. I’ve heard Europe has the opposite view because their walled cities were their defense against roaming criminals and invaders. There’s also the legacy of slavery and redlining, where some of the opposition to cities takes on a racist tinge. All those are tightly wound into American society and hard to unravel. So we just have to do everything and maybe some of it will help.
There’s a guy on YouTube, one of those investment opinionators, who bought a house in Las Vegas that’s 8000 square feet if I heard it right. To me 2000 square feet is already large, and this is four times larger. It’s not even a one-off: it’s an ordinary house in brand-new tract development, where all the houses are presumably that big. He calls it a middle-class bargain, since house prices are relatively low in Las Vegas. so people are buying huge houses instead of saving 3/4 of the money with a smaller house. As far as I can tell it’s only him and his wife living there, so 4000 sq ft each. I wouldn’t even know what to do with all that space, and I wouldn’t want to maintain it or air-condition it.
I’m just salty, is all. If commercial concrete can be made to capture carbon instead of produce it, that’d be huge.
However, resuming the historic patterns of progressive densification of housing and transit in productive centers is a much simpler step. Frankly, the historical disdain for cities comes not from some arcane truth, but from them being places of concentrated pollution and cultural heterogeneity.
The disdain for cultural diversity may be an innate feature of human xenophobia and elder preference for stability (most often in the form of cultural homogeneity, also very common in European cities).
However, urban pollution was largely conquered in the 20th century with mass electrification and environmental cleanup regulations, but obviously the transition away from dense electrified transportation in the mid century was a major setback in the reduction of air pollution.
When I talk to older generations who live in suburban neighborhoods, they express belief in a litany of reasons why the suburbs are the ultimate form of human civilization. Other than the obvious dissonance inherent in how these suburbanites love visiting urban places but refuse to consider them “livable”, the only true through-line I see is a disdain for being around folks in socioeconomic classes and ethnicities visibly different than theirs. Maybe that’s universal too, but my extreme frustration stems from privileged suburbanites enforcing exclusionary rules that prevent cities from growing and thriving because their home was built in an era of mistaken myopic modernism (not to speak of the rampant racism).
These are people who are simply afraid of change, afraid of consequences, and afraid of being forgotten. Their fear of the unstoppable march of time combined with selfish audacity drives them to freeze their neighborhoods in amber as if that will prevent them from being forgotten. And sure, it keeps their neighborhood static and stable. Meanwhile, jobs grow in city cores and the only new housing is built on city edges, and the resulting environmental and social devastation only recently being felt by more than the observant few.
I’m just salty. I’m only able to afford a house in a neighborhood of my choosing because of generational wealth that most people don’t have, and there are so many empowered idiots out there who don’t understand how that’s kneecapping the ability of American cities (and America in general) to compete with cities in countries that are actually building sustainable housing and transitioning to sustainable and efficient transportation networks.
But hey, what do I know.
I mostly agree with you, but then you admit to having a house due to generational wealth? So it’s ok for those with generational wealth to have houses? I mean, nothing is stopping you from living more sustainably now or having a lovely, luxury condominium with your generational wealth. Why do you make this choice?
There are some issues still with urban living, that isn’t just not liking the poor. As a 26 year resident of Capitol Hill (Summit and Olive) in multi family housing, I can tell you noise is a real thing. Also, construction of 5 over 1 condos/apartments often is wood frame, which is not great for preventing noise. (Yes, this can be mitigated in theory – but are landlords and condo boards willing to do so). As I get older, my tolerance for noise decreases.
There is also the mental health crisis. I have spoken with many, many people with very obvious mental illness waiting at bus stops for example. While it isn’t always a negative experiences, over the years it wears on one’s psyche. It saddens me in my 26 years here, despite all the good talk and taxes, the problem just gets worse. Getting called “f****t” by mentally ill street people has been a constant for me.
I understand where you are coming from, but it sounds a bit off for you to judge others who are making the same basic choice you are. Writing about urbanism isn’t the same as living it. There are valid reason to want, if one chooses, to live in a SFH (as you well know).
People can choose a smaller house for other reasons, like the environment, walkability, or just not having a house that’s irrationally huge. In the 1950s the average house size was 1000 sq fit, then it ballooned to 1500, 2000, and 2500. In New York City there are even apartments 2000 or 4000 square feet, where you can live in luxury and I’m sure they’re soundproof. The fact that people are buying >3000 sq ft houses anyway in spite of not havng a 10-person family shows they don’t care about any of those, and that’s an indictment of their values and worthy of discussion. Especially when people in other industrialized countries don’t do this and the US is an outlier. Society has also urged people over the years to recycle and quit smoking, so how is this different? There’s also the externalities to everyone else in building such large houses and ultra-low-density neighborhoods; e.g., energy, raw materials, and do those materials come from an authoritarian country? Why should they be able to impose those externalities on everyone else.
A neighborhood of 8000 square foot houses with proportionally-sized yards and SUV-sized streets clearly can’t be walkable to anything. That raises questions of whether they should be allowed. Especially, entire new neighborhods of them.
“you admit to having a house due to generational wealth? So it’s ok for those with generational wealth to have houses?”
My generational wealth was in the form of education and job opportunities. I inherited from my dad the grand total of $500, a TV, and a suede jacket. My mom is too poor to leave anything because her pension is small and she has large medical expenses. I live in an apartment, and if I ever get anything else it would be a condo or a small house. I’m not completely against houses or people with multigenerational wealth having them. It’s just that the American average and cultural middle is too house-heavy and car-dependent.
I don’t conflate houses and homes – condominiums and dense townhomes are my preferred form of housing. Besides, all the new construction of a comfortable size is still out of reach of most folks trying to actually keep their rent instead of forking it over to some absentee landlord. Every city I’ve ever lived in is still struggling to overcome the idiotic late-1900’s idea that stagnant housing and a strong filter for wealth is somehow inherently good for cities, when all available indicators are showing that it’s literally retarding civic growth and social advancement.
I should have used the correct tense to indicate that I will be able to afford comfortable housing because of generational wealth – I’m still a renter. The power dynamic I want to break is the one that makes cities like Seattle only be truly accessible to people who look like me and have generational wealth like me. No one argues in good faith that tract housing should be banned inside of established UGAs. But, what needs to be un-banned is the other end of the housing spectrum. Although that may be hard to see from the perspective of a long-time resident of what’s considered part of Seattle’s Urban Core, all I’m saying is that maybe we should get our governments to figure out how to make 2, 3, 4+ bedroom condominiums and townhomes feasible and accessible to folks who aren’t making 2+ times the AMI in the neighborhoods between the major centers of the city. “Apodments” et al. are fine and worthwhile, but if the non-upper class can’t afford to live comfortable within a walkable or ridable distance from their workplace, then we only have our onerous policies and politics to blame.
I’m not purporting that the simple legalization if dense housing will fix all social problems. And yes, wanting peace, quiet, and stability is a natural desire throughout life, and tolerance for a lack thereof disappears as energy wanes. But I see what progress is easily being achieved elsewhere (e.g. https://twitter.com/holz_bau/status/1505692566477438979) and I have fight hard against the idea that comfortable urban living for all who want it is impossible in any plausible conception of American cities.
[Most American energy usage is in heating too-large, separated houses and powering too-large, underutilized automobiles ]
Residential is only 17% energy consumption and
ALL transportation is 35%.
I’ll move my goalposts by amending my assertion to say that “most obviously excessive American energy usage is likely the result of terrible land use policies and housing culture”
My evidence being the relative energy usage per capita of the USA versus other Western nations.
Nathan is right, and it all goes together. You live in a bigger place, farther away from everywhere you want to go. It is too far to walk to places you would visit regularly. Even if you want to take transit, it isn’t very good, because transit doesn’t function that well in that environment. You use more energy in part because you are heating a bigger place, but also because of transportation.
Even if I haven’t nailed the explanation, there is clear evidence of an inverse relationship between density and global warming footprint. Check out this map of carbon footprint per household by zip code: https://coolclimate.org/maps. Now zoom in on *any city*. It all follows the same pattern — as you get to more density, the carbon impact (per capita) goes down. This is astonishing, given that urban areas often have more wealth. This relationship is strong enough to counteract the relationship between wealth and carbon impact. It also cuts across cultural lines. This happens in cities not known for their environmental ethos, as well as low density suburbs that are full of environmentalists. Increasing density is the simplest, easiest way to reduce our carbon impact in the long term.
But there is a huge cost in the short term, and concrete plays a big part of that, as the video explained. Urbanization involves concrete, and concrete, right now, has a very large carbon footprint. If we can make concrete that is closer to carbon neutral — or better yet, sequesters carbon — it would be a huge part of the solution.
That is an interesting map Ross. It measures average household carbon emissions, not per capita emissions. For example, for 18 years I lived in a 2400 sf SFH with two kids, or 600 sf each. Our household carbon emissions would be more than say a studio with one tenant in Seattle just based on GFA (although carbon capture from the yard should also be factored in) but not our per capita emissions. It would be like measuring carbon emissions from a full diesel bus and a car with a single driver and stating buses emit more carbon than cars.
I think if the goal is to change how people want to live to lower carbon emissions that approach won’t work in America. One of the biggest differentials in carbon emissions between urban areas and suburban areas (which never factor in carbon capture from yards) was suburbanites were required to commute to urban areas to work, and even transit commuters emit carbon. EV’s were supposed to solve that problem, but WFH beat EV’s to it. Good for the environment, potentially damaging to urban cores and transit.
When it comes to the other major source of carbon emissions, electricity generation, I simply don’t understand why building codes don’t require new houses to have solar panels (although that is probably trickier in multi-family housing). It seems such an easy fix. Many think EV’s will end up as the electricity storage source through smart metering that has been the holy grail, and will ameliorate the demand during peak usage, and I think that is probably correct.
If we tell Americans to switch their preferred housing to stop global warming they won’t do it, and I am not sure the science is really there about density, and not surprisingly urbanists and transit advocates are the biggest advocates for density solving global warming. WFH, EV’s, smart metering, solar panels on rooftops, and ending work commuting, will balance out carbon emissions per capita between urban areas and suburban areas, and then folks can live wherever they want, which is what they will do anyway.
For me personally, we plan to move our office from downtown Seattle in June (the building has refused to release us from our lease early since the building is mostly empty) to within walking distance from my home on MI, and I imagine my next car will be electric. Now that we have four back in the house (temporarily) my guess is my per capita carbon footprint (including carbon capture from the yard and trees) will be lower than most on this blog. In suburbia no less.
Lawn carbon capture is laughable.
In 2016, commuting was 15% of trips, and so WFH is not the grand savior you think it is.
Like I said, few will argue in good faith that SFH should be banned. What needs to happen is that dense housing should be un-banned from the rest of the city. Then the market can handle whether people are willing to pay for the cost of a lawn within walking distance of a civic core, or if it’s more efficient to erect structures that allow many people to live where they want, instead of only one person.
I’d you’re going to count carbon captured by your lawn, you have to also count the carbon emitted by your landscapers when they mow it, blow it, and drive their truck to and from it. I am sure the carbon emitted in maintaining a lawn far exceeds the carbon captured by the lawn.
Yes, it is possible to buy electric lawn equipment, but only if you are willing to all of the yard work yourself. Commercial landscapers use their own equipment, and it’s almost always running on gasoline.
And, of course, the fact that come to mow and blow the lawn every week like clockwork, whether the grass has actually grown or not doesn’t help.
Asdf2, for the record I don’t have any lawn. My yard is mostly mature trees: Fir, Beech, Elm, Cherry, Maple, Birch, Cedar. We do have a gardener every two weeks, and have had the same guy for over 20 years. I helped him complete the immigration paperwork for two relatives from Mexico who naturally work for him. It is a pretty good living for someone arriving in this country with little education and unable to speak English.
Since Mercer Island requires large minimum lot sizes and yard setbacks the house footprint and all impervious surfaces are limited to 45% of lot size, so mature trees are preserved, especially under the new tree ordinance. Mature trees are a critical element to the character of a SFH neighborhood. Seattle has IMO been negligent in maintaining mature trees.
It’s true carbon is emitted when green spaces are landscaped, whether the UW campus, the Arboretum, parks, and any green space. Leaf blowers are used to maintain parking lots, sidewalk’s ,and concrete surfaces too. Are you suggesting we get rid of all green spaces, or not maintain them?
Cities like MI are looking at legislation to require electric tools. The carbon savings are low, and the costs to these mostly small immigrant landscaping businesses high. But as cordless tools get better cities will move towards electric tools, although 37% of PSE’s electricity is from coal, and less than 10% from renewables. The real complaint in neighborhoods today is the noise from leaf blowers due to WFH, and I wish they were better muffled.
Push lawnmowers still exist.
I’m bothered by gas-powered leaf blowers. Every morning I get this horrible noise from my apartment building and surrounding buildings as they blow off the concrete decks and alley. Chainsaws are annoying too.
Parks allow a community to share a lawn, so it’s less lawn acreage overall. Homeowners who plant trees, shrubs, vegetables, pollinating plants, bioswale grasses, etc, are to be commended. Some private lawn space is OK but we should get away from large lawns just for decoration or most of the yard.
I’ve read that large lawns started in England, where the climate is wet enough that they don’t need watering.
P.S. I still want to do a walking tour on Mercer Island. Do you have any suggestions of places to go or how to minimize hills (or to concentrate hills into one steep block)? Where do the large-lot houses start in relation to the P&R? I’m thinking of going to the Stroum Center and down Island Crest Way, and I’m not sure about West or East Mercer Way. It looks like East Mercer Way has the biggest hills but may have more unique things to see.
It’s VMT, not trip count, that matters.
The key thing about electric lawn equipment is that 2-stroke motors are very polluting, much worse than 4-stroke motors used in vehicles. For a city with bad air pollution (LA, SLC, etc.), banning gas powered leaf blowers can be as important as electrification of trucks & cars.
RE lawns: https://www.strongtowns.org/journal/2017/7/28/grassy-lawns-exist-to-prove-youre-not-a-peasant
I don’t think you understand AJ: the biggest opponents of banning gas powered yard tools are city park departments, large green space areas like the UW and Arboretum, and private gardens. All my yard tools are battery powered because gas requires spark plugs and changing out the gas for winter. But I don’t have a city to maintain.
The reality is banning gas powered yard tools is silly in the big scheme of things, and makes climate advocates look silly, which is why they tend to ignore the issue, especially since the rest of the country doesn’t get the heavily subsidized benefit of hydro power whose harm to fish and massive carbon footprint from the concrete alone (which is still curing) is ignored as Seattle does.
The folks “opposed” to gas powered lawn tools are urbanists, as though that will somehow reverse the deurbanization happening today.
Wouldn’t it be lovely if we could solve our transit issues and decline of our major urban centers and global warming by having poor Hispanic landscapers switch to expensive battery powered lawn tools that are mostly recharged from electricity generated by coal and gas. Unfortunately the city of Seattle and UW don’t see it that way.
Having driven by the under-construction East Main St. station several times lately, I notice what looks like a gate south of the station separating Surrey Downs Park from 112th St. Putting myself in the shoes of a local resident walking to the station, the walk is about 1/4 mile shorter if the gate is open vs. if it’s closed (requiring a detour north to Main St.). Opening the gate also makes the park available to people living in whatever TOD gets built east of the station, who would otherwise not have a park within an easy walking distance of their home.
I would hope Sound Transit would be considerate enough to open the gate and, if necessary, install a pedestrian signal for the track crossing. But, of course, it is easy to imagine Sound Transit doing the opposite. Sound Transit deciding that people can’t be trusted to obey a signal and look both ways, even in an area with clear visibility and trains not going that fast, due to the nearby station. Nor is it difficult to imagine Sound Transit intentionally blocking off the neighborhood because that’s what the people who attended the design review meetings asked for. I’m imagining neighborhood feedback dominated by elderly people who will never ride the train, but are deeply afraid of riffraff from the TOD (god forbid) crossing the street and sharing their park to walk their dog.
That gate is for emergency vehicles; ST will keep the gate closed to prevent private vehicles from passing through, but I’m not sure about pedestrians. 11th still has direct access to the north side of the station, so it’s still pretty easy to walk into the Surrey Downs neighborhood from the station.
Check out the 3.40 mark: https://www.youtube.com/watch?v=fF-Di9uGKZc
Did Russia really use more energy in 1984 between 1977 and 1985 than it did afterward, and it dropped again in 1996? I wonder if that’s related to its population loss, although I thought that started later. I can’t imagine that it grew more conservationist. Especially since natural gas was free in the 1990s at least, so people overused hot water, and I saw one man who kept his stove burner on low so he wouldn’t have to spend money on matches to light it. (His money went to vodka instead.)
Mostly loss of industrial base, rather than residential construction, I’d speculate. 1996 would be when Russia had a currency crisis and its economy basically collapsed. Much of that energy consumptions has either moved to Asia or been replaced my more energy efficient factories in eastern Europe/Russia.
The currency crisis was in 1998. I was in Russia in September 1995 when the ruble was 4500 to the dollar, and in September 1996 when it was 5400 to the dollar.In January 1998 the government lopped off three zeroes and replaced it with a new ruble at 6 to the dollar. The currency crisis happened later that year, and by 2000 it had dropped to 30. In 2021 it reached 80, and with the invasion it dropped to 110 and is now 107.
In the early 90s people used dollars for transactions, but just before I went a new law required rubles to be used for cash transactions, so people switched to using dollars just for savings. Retail prices were at dollar-equivalents and changed with the exchange rate, or some remained rounded to 1000. Interest on bank deposits was 10% a month (120% a year) to compensate for inflation.
Now that the economy and media and laws are reverting to Soviet patterns, I wonder if something like this will come back.
Russian’s population is more or less the same now as it was in 1985, so I assume it was all related to industrial changes towards the end of the Soviet Union and following its demise. Towards the end of the Soviet Union the economy was going downhill, and in the early days of the new Russia, it was a mess.
There’s an entrance to the street that’s for emergency vehicles. ST made that clear during the South Bellevue open houses. It replaces a SE 8th Street station that was nixed when Main Street became a station. I don’t see how it helps people walk to the station since it’s so far south of it, so are you talking about another gate on the north end of Surrey Downs? And since it’s mainly blocking cars, are you sure pedestrians can’t go through the sides?
Yeah, it’s pedestrians I’m asking about. Cars can easily go around.
City Beautiful favors banning cars from main streets. Focus on three cities that have done so: San Francisco’s Market Street; Madison, Wisconson’s State street; Manhattan’s 14th Street. In all these cases traffic on surrounding streets didn’t noticeably change, and the street is much more pleasant for pedestrians and bike riders. The 14X express bus got eight minutes faster. That reminds me of how ST improved the design of Stride North and shaved off some twenty minutes from it. Of course, car supremacists would not be amused, But congestion on the side streets didn’t increase much; the car trips just vanished so they must not have been essential.
Stride North improvements were more about leveraging the HOT lanes greater than in the representative project (to 196 rather than Brickyard)?
Banning cars from 3rd is probably a better comparison?
Not sure when you were last on Market St., at least lower Market, but it is very dangerous in a city that generally is pretty safe. I attended a legal seminar at the new Federal Building on lower Market a few years ago and was told don’t walk around lower Market at night.
Unfortunately, they told me that after I had walked from my hotel along lower Market to an opening cocktail party. Along the way I witnessed a vicious assault by a female pimp wearing a colored mop on her head for a wig and obviously her prostitute. I called 911 but they only wanted to know if I was ok. I was glad I was with another guy on the walk because it was scary (especially in a suit and tie).
I don’t have a problem with a city designating an area pedestrian only (and love San Antonio’s River Walk) except they still have to allow folks — including in cars — to drive and park nearby to access the pedestrian area, and it has to be safe to walk around. I can’t imagine there are any pedestrians strolling around lower Market at night, with or without cars. The cars are not the issue.
The one big improvement in San Fran has been Uber. In the past the restriction on taxi licenses made it impossible to get a taxi, parking is expensive, and San Fran like NY is a city designed for Uber or cabs (bus service is terrible and the riders often sketchy and the trolley is mostly a tourist attraction with huge lines to go nowhere). Now with Uber it is very easy to quickly get an Uber for a reasonable price, which really makes so much more of the city accessible (if it is safe). San Fran like NY is a city with the true density to make Uber fares very reasonable to get from one part of the city to the next.
Escalator Outages (3/21/22):
Link – SeaTac Airport Station, #002
Link – Capitol Hill Station, #002
Link – Capitol Hill Station, #008
Link – Northgate Station, #002
Link – Northgate Station, #003
Plus six at Westlake Station, one at Pioneer Square Station and two at ID/Chinatown Station.
Two escalators out at Northgate Station? Really Sound Transit?
It was bad all last week at Northgate (that’s my home stop) after at least a week where it wasn’t as awful.
It’s truly amazing how incompetent ST is with escalators… brand new stations that can’t go a week without multiple escalators breaking down. A complete failure.
Not only the escalators. The south-end elevator from mezzanine to plattorm has been making the most godawful scary noise for a long time now….
Thank you The Urbanist for this recent tweet.
It is interesting and sad that some of the biggest profit winners of C02 capture techniques are the oil companies due to government rewards.
I haven’t visited this website for a long time. The choir is much the same. Except no Mark Dublin?
Sadly, Mark Dublin passed away recently.
There’s a comment thread a month or two ago in memorial for him. I’m not having luck searching for it but maybe you can find it.
I couldn’t find it either. It was a few months ago, if someone else has better luck.
From what I can glean online Mark was living in Olympia at the time of his death.
Yes, he lived in Ballard for many years, but then his rent went up substantially and he got displaced. The best deal he found was in Olympia. He said it was right near the capitol and city center and was walkable. He didn’t intend to come to Seattle much, but then he got several jobs here, I guess short-term projects, so he was our commuter-reporter from Olympia. He liked to stopover at Freighthouse Square, take the 574 to SeaTac, walk through the airport and stop at a restroom, and take Link the rest of the way to Seattle.
I am so sorry to hear that Mark Dublin is no longer here. I always enjoyed reading what he had to say.
Thank you all very much for letting me know what happened and sharing links.
Just a reminder that ST is seeking Everett Link feedback:
While I responded, I really feel that no alternative should be summarily dismissed because there is no cost nor ridership no needed station footprint nor accompanying pedestrian circulation plan. It feels very arbitrary to opine on the best station choices without these basic information building blocks.
Unfortunately, this is just another terrible chapter of ST forcing early choices without useful information that keeps creating awful ST extension outcomes. ST PLEASE STOP THIS ARBITRARY SCREENING!!!
Sound Transit just published CEO Rogoff’s recent letter to current FTA Director Fernandez to notify the federal agency of their intent to get four extension projects into the CIG pipeline, specifically for New Starts funding.
Here’s the opening paragraph from Mr. Rogoff’s correspondence:
“With this letter, I am transmitting requests to the Federal Transit Administration (FTA) to admit two Sound Transit projects into the Project Development phase in the Capital Investment Grant (CIG) program New Starts category. Together, these two extensions make up the West Seattle to Ballard Link Extension project. They are designated in these requests as the West Seattle to SODO segment and the SODO to Ballard segment. These are the first two of four major projects for which we anticipate seeking admission into Project Development in the months ahead, the next being the Tacoma Dome and Everett Link Extension projects.”
Tell me again why ST thinks they can get off with just doing one combined EIS for the West Seattle Link extension, the DSTT2 and the Ballard Link extension. Given the large scope involved this just seems crazy to me.
The rest of the CEO’s letter can be found at the link that follows.
I started reading the DEIS reports, and many of those are split into two segments! See Chapters 3 and 4 of the DEIS here: https://wsblink.participate.online/
I am thinking that the one DEIS was a legacy choice from 2017-18 when the WSBLE studies started. And we all know how ST hates to admit re-examining a prior choice.
However, by calling it two projects for New Starts as mentioned in the letter, I would think FTA will de facto separate these into two projects. The New Starts hurdle is more rigorous than environmental review anyway.
I’m increasingly thinking that ST sees the DEIS as a chore rather than an opportunity to re-examine the preferred alternative.
“I’m increasingly thinking that ST sees the DEIS as a chore…”
I agree, sadly.
Why does it matter if it’s one EIS or two, other than that they can go at different speeds?
In one word, litigation.
Exposure to such is increased with the ST strategy of including multiple projects into a single NEPA review. The goal from the project sponsor’s point of view is to get to the ROD without additional delays caused by potential challenges.
Additionally, CEQ’s regulations require that EISs identify those alternatives that have been eliminated from detailed study (i.e., impacts analysis) because they are unreasonable and briefly discuss why they have been eliminated. That’s a requirement under 40 CFR 1502.14(a). Thus, this becomes another avenue for challenges to arise, particularly with a highly complex EIS.
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