Permitting Guide
12 min read
Common Risks in Draft Permit Documents
The most frequent errors that lead to Requests for Additional Information (RAI) and project delays.
1. Insufficient Purpose and Need Statement
A narrow or poorly defined "Purpose and Need" statement is one of the most common reasons for successful legal challenges to NEPA documents.
2. Failure to Consider a Reasonable Range of Alternatives
Agencies must consider all reasonable alternatives to a proposed action. Omitting a viable alternative is a frequent procedural error that leads to remands.
3. Inadequate Cumulative Impact Analysis
Failing to account for the combined effects of the proposed project and other past, present, and reasonably foreseeable future actions is a major source of litigation risk.