6 
individual actions will be necessary where 
such actions have significant environmental 
impacts not adequately evaluated in the 
program statement. 
40 C.F.R. § 1500 . 6 (d) (1) (emphasis supplied). Moreover, CEQ has 
strongly endorsed program statements in its Fifth Annual Report 
entitled "Environmental Quality" (December 1974) (at p. 413, 
emphasis added) : 
The Council has strongly encouraged agencies 
to prepare program statements. Frequently, basic 
policy issues in the operation of a program can be 
addressed only in an analysis which covers the 
whole program; at the project level, it is often 
not feasible to review these basic questions. In 
addition, preparation of a program statement may 
allow an agency to dispense with the preparation 
of impact statements on individual projects, provided 
that impacts at the site are not substantial . Even 
if such impact statements cannot be dispensed with, 
however, they can often be reduced in size if the 
program statement already covers many of the impacts. 
Thus, preparing program statements may help to 
increase the efficiency of the NEPA process. 
Also, CEQ has stated "[i]n particular we are interested in finding 
ways of consolidating numbers of impact statements into fewer 
but broader and more meaningful reviews." CEQ, "Recommendations 
for Improving Agency NEPA Procedures", quoted with approval in 
Natural Resources Defense Council v. TVA (Coal Purchases) , 367 
F.Supp. 122, 127 (E.D. Tenn. 1973), aff'd, 502 F.2d 852 (6th Cir. 
1974) . These CEQ interpretations of NEPA should be given "great 
respect" by this Court. See Sierra Club v. Morton , 169 U.S. App. 
D.C. 20, 514 F.2d 856, 873 (D.C. Cir. 1975), rev'd on other grounds, 
sub. nom. , Kleppe v. Sierra Club , 427 U.S. 390 (1976). 
In Coal Purchases , supra , the Sixth Circuit affirmed 
the trial court's opinion which held that TVA, which had 
prepared a programmatic impact statement on its purchases of 
coal, did not have to prepare individual impact statements on 
each specific coal purchase contract. 
[Appendix C — 114] 
