(dissenting):
In the foregoing opinion, the majority has remanded this case with instructions that it be held in abeyance pending the issuance of a “study” presently being prepared by the Federal appellees. It is anticipated that the release of the study will enable the various agencies involved to decide within 30 days thereafter whether “a comprehensive, programmatic impact statement for the Region” 1 is necessary. Since I conclude that a regional environmental impact statement (EIS) is not presently required in these circumstances, I find no need to remand the case for further proceedings and accordingly dissent from the action of the majority.
The only immediate practical effect of the majority's decision is to continue the temporary injunction as ordered by this court on January 3, 1975, in order to “preserve . . . the status quo.”2 My objections to the continuance of this injunction are the same as were indicated in my dissent to the original order. See Sierra Club v. Morton, 167 U.S.App. D.C. 756, 509 F.2d 533, 534-36 (1975).
I
The trial court concluded that appellants’ complaint failed to present a justi-ciable case of controversy because
the courts will not review the validity of supporting statements or studies until final federal actions [are] taken under NEPA section 102(2) and until after final agency action has been taken with respect to the individual project.3
While the majority concedes that “as a general proposition of law NEPA challenges to individual projects can be brought only after final agency approval of a project,” it interprets Scientists’ Institute for Public Information, Inc. v. AEC (SIPI), 156 U.S.App.D.C. 395, 481 F.2d 1079 (1973), as holding that a challenge to a comprehensive program need not be made through an attack on an individual project.4 As indicated hereafter, the record in this case does not establish the existence of any comprehensive regional program of the type found in SIPI which could justify requiring the preparation of a regional environmental impact statement at this time. However, even if one concedes that such a statement might be appropriate, the District Court was still correct in concluding that an action divorced from the review of a statement covering an individual project is not a proper means for the determination of appellants’ claims.
In deciding that the instant ease is a proper vehicle for raising a claim for a regional EIS, the majority has overlooked the required relationship between the statements prepared on individual projects and the “regional” statement appellants seek. If appellants are cor*885rect in asserting that NEPA requires the preparation of a regional EIS before any development of the Northern Great Plains may proceed, then all the statements covering individual projects necessarily must be at present insufficient to comply with NEPA. Conversely, if an EIS on an individual project is found to comply with NEPA, it necessarily follows that NEPA does not require the preparation of a more comprehensive statement before that project may proceed.
Impact statements have already been issued for the Westmoreland mine, the Peabody Coal Company project, and four mines and a railroad right-of-way in the Eastern Powder River Basin. See Supp. Finding on Remand, H 9a. Of these, the Westmoreland EIS was found to be sufficient under NEPA in Redding v. Morton, Civ. No. 74 — 12—BLG (D.Mont., May 1, 1974), appeal pending, 9th Cir. No. 74 — 1984, and the remaining statements apparently have not yet been challenged in court.5 My dissent to the issuance of the temporary injunction states, and I continue to believe, that the proper method to use in assessing the need for a regional statement is for appellants to file an appeal challenging the sufficiency of the EIS covering an individual project.6 Appellants’ apparent inability to successfully challenge the statements on individual projects as too limited in scope is strong, if not compelling, evidence that a “comprehensive regional EIS” is not required at this time.
ii
The starting point for any discussion of the need for an environmental impact statement is of course section 102(2)(C) of the National Environmental Policy Act (NEPA), 42 U.S.C. § 4332(2)(C):
(2) all agencies of the Federal Government shall—
***:}:* *
(C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on—
(i) the environmental impact of the proposed action,
(ii) any adverse environmental effects which cannot be avoided should the proposal be implemented,
(iii) alternatives to the proposed action,
(iv) the relationship between local short-term uses of man’s environment and the maintenance and enhancement of long-term productivity, and
(v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.
The crucial question here is whether the Federal appellees have “proposed” “major federal actions” which require the preparation of an EIS covering all coal-related development in the “Northern Great Plains Region.”7
*886To place this case in perspective, it is important to keep in mind exactly what is not at issue. The federal appellees do not deny that they are taking actions related to coal development within this region. On the contrary, several projects are admitted to be in various stages of development, and the agencies have consistently prepared impact statements prior to taking action.8 Nor is there any contention that the projects which have been approved or which may be approved in the future are not “major.” Furthermore, the agencies have consistently required that the EIS on each project consider the cumulative environmental impacts of related developments.9 Where appropriate, they have prepared impact statements which consider together several related developments within an area.10
*887What appellants present to this court is a claim that all these good faith efforts on the part of the various agencies are not sufficient to satisfy the demands of section 102(2)(C). To carry out the alleged requirements of NEPA, appellants assert that before any development in the region may be allowed to go forward, the agencies concerned must first prepare a “comprehensive” analysis of the environmental impacts of all present and potential development within the region.
Ill
By reversing the decision of the District Court, the majority is indicating its belief that there is some substantial possibility that appellant’s claims will ultimately be successful. To reach this conclusion, the opinion reasons that major federal actions can be combined to create a new major federal action for which an EIS is necessary. Its authority for this proposition is this court’s decision in Scientists’ Institute for Public Information, Inc. v. AEC (SIPI), 156 U.S.App.D.C. 395, 481 F.2d 1079 (1973) and the Second Circuit decision in Conservation Society of Southern Vermont, Inc. v. Secretary of Transportation, 508 F.2d 927 (2d. Cir. 1974). There is no doubt SIPI holds that a comprehensive statement may be required in certain circumstances, but like any holding it is colored by its facts and its reasoning. The difficulty arises in the application of that decision to the facts here.
The crucial consideration which justified the requirement of a statement covering more than an individual project in both SIPI and Conservation Society was the presence of irretrievable commitments of resources beyond what was actually expended in an individual project. In SIPI, each development in the Liquid Metal Fast Breeder Reactor Program made it more unlikely that the agency could in the future abandon its investment in favor of some alternate energy source:
The manner in which we divide our limited research and development dollars today among various promising technologies in effect determines which technologies will be available, and what type and amount of environmental effects will have to be endured, in the future when we must *888apply some new technology to meet projected energy demand.
481 F.2d at 1090. Similarly, the court found in Conservation Society that the construction of a 20-mile segment of highway would generate traffic and thus create pressure for further construction along the entire route and foreclose consideration of alternatives to highways.
Phrasing these decisions in terms of the potential “regional” development at issue in the instant case, it is clear that the courts in SIPI and Conservation Society found that a federal action at one point in the “region” would cause a ripple effect which would eventually have an impact on future federal actions elsewhere in the “region.” Because of this effect, each court determined that the agency involved was required to prepare a comprehensive statement for the entire “region” before it could approve an individual project within the “region.”
The reason for the above holdings becomes clear when one considers the purpose underlying the preparation of impact statements. Virtually every federal action “significantly affecting the quality of the human environment” will necessarily involve some irreversible and irretrievable commitment of resources. NEPA only requires that the agency disclose these environmental costs and consider them in arriving at a decision; it does not prevent an agency from proceeding with a project if the benefits outweigh the costs disclosed in the EIS. Thus where the only irretrievable commitments of resources are those directly associated with an individual project, an impact statement covering that project is sufficient to enable the agency to act. However, in situations where the dedsion on one federal project was found to presently cause irretrievable commitments on future projects or the foreclosure of future options, this court and the Second Circuit quite properly found that an EIS for the entire project was necessary before the initial step could be taken.11
Applying the above analysis, the instant case is readily distinguishable from both SIPI and Conservation Society. Any coal-related federal action will undoubtedly require certain associated developments. For example, the approval of a mining plan will most probably require the granting of rail rights-of-way and the construction of housing facilities for mine employees. However, these are direct consequences of the initial action, and the agencies involved have always taken the position that such impacts must be considered in the EIS which precedes approval of the mining plan. This record is devoid of the type of commitment of “regional” resources which justified the results in SIPI and Conservation. Society. Developments in one part of the Northern Great Plains are essentially independent from developments elsewhere in the region. For example, the decision to permit mining of sub-bituminous coal in Wyoming, to which the Federal Government has the mineral rights, in no way commits Interior to approving proposals for mining lignite, similarly owned by the United States, in North Dakota. Even within each of the Basins which comprise the Region, development of some portion of the coal reserves does not irretrievably commit the federal agencies to permit development of the entire reserve. Furthermore, it is clear that even the larg*889est of the proposed projects will not have an environmental impact on the entire Northern Great Plains Region. It may indeed be the case that widespread development of this area will eventually occur, but the impetus for that development will come from the nation’s need for coal and not from the fact that partial development of the region has been allowed.12.
IV
If SIPI and Conservation Society were the only relevant decisions, the majority’s arguments might have some appearance of validity. However, several courts have considered arguments such as those advanced by appellants, in cases which presented facts that were considerably closer to the instant case than SIPI and Conservation Society, and have determined that a “regional” EIS was unnecessary before individual projects within the “region” could be approved. See Trout Unlimited v. Morton, 509 F.2d 1276 (9th Cir. 1974); Sierra Club v. Stamm, 507 F.2d 788 (10th Cir. 1974); Sierra Club v. Callaway, 499 F.2d 982 (5th Cir. 1974); Environmental Defense Fund v. Armstrong, 356 F.Supp. 131 (N.D.Cal.), aff’d, 487 F.2d 814 (9th Cir. 1973); Jicarilla Apache Tribe of Indians v. Morton, 471 F.2d 1275 (9th Cir. 1973); Movement Against Destruction v. Volpe, 361 F.Supp. 1360 (D.Md.1973).
In its attempt to evade the clear holdings of these cases, the majority dismisses them with the assertion that:
Every cited case involved the propriety of an injunction against an individual project pending completion of a regional EIS or other study. None of the cases involved a direct challenge to the need for a regional EIS.
Majority Op. at n. 29. This is a classic example of a distinction without a difference. Surely, it is not reasonable to suggest that the decisions reached by other courts are somehow less sound because they were able to assess the need for a regional EIS in the context of a challenge to the sufficiency of a specific statement whereas this court is considering a challenge in the abstract without ever determining that a particular EIS does not comply with the dictates of NEPA. If any inference can be drawn from the majority’s distinction, it would be that the cited cases are entitled to considerably more weight than this court’s decision in the instant ease.
In Jicarilla, supra, the court rejected contentions that impact statements issued in connection with each of several coal-fired electric generating projects in four southwestern states violated NEPA because they were issued prior to the completion of a Southwest Energy Study by the Interior Department. The májority is correct in pointing out that the plaintiffs in Jicarilla were specifically seeking delay pending the completion of a “study” rather than delay pending the preparation of a regional EIS, but rather than forming the basis of a distinction, this fact emphasizes its similarity to the instant case. The Southwest Energy *890Study “was designed to evaluate the problems created by further development of coal-fired electric power in the Southwest;” (471 F.2d at 1279), a purpose quite similar to that of the Northern Great Plains Resources Program study. The Majority opinion at this point apparently overlooks the fact that its opinion ultimately does not direct the preparation of a regional EIS for the Northern Great Plains but rather just arrests development within the region until the study issues, at which point the need for a regional EIS would be assessed. The Ninth Circuit found that this sort of delay was not mandated by NEPA, and my conclusion on the facts of this case is to the same effect.
In Environmental Defense Fund v. Armstrong, supra, the Ninth Circuit affirmed a District Court decision rejecting an argument that an EIS covering the New Melones Dam project was inadequate because it did not include a “comprehensive study” covering the entire California Central Valley Project. Although the plaintiffs once again requested only a study and not a regional EIS, the language of the District Court is instructive:
Under these circumstances there is no requirement under NEPA that the EIS with respect to the New Melones Project be delayed until a comprehensive study of the Central Valley Project be completed. So long as each major federal action is undertaken individually and not as an indivisible, integral part of an integrated state-wide system, then the requirements of NEPA are determined on an individual major federal action basis. Plaintiffs’ suggestion that there is need for a comprehensive study of the Central Valley Project should be made to the Congress, and not to the Court.
356 F.Supp. at 139. As is stated above, the federal actions related to coal development in the Northern Great Plains fall largely into this same category. The majority notes that the court in Armstrong refused to wait for the study because no comprehensive study had been commenced, and therefore finds the case to be in sharp contrast to the instant case where the NGPRP Study is under way. It is revealing, however, that the majority does not find this fact to be of significance in its discussion of Jicarilla where the Southwest Energy Study had been released by the time the case was decided.
The remaining cases cited on supra, 169 U.S.App.D.C. at -, 514 F.2d at 889, involved demands that a comprehensive EIS be prepared prior to the approval of individual projects and thus are squarely on point with the instant case. In Sierra Club v. Callaway, supra, the Fifth Circuit reversed a District Court decision which had ordered that construction of the Wallisville Reservoir project be held up pending the preparation of an EIS covering the entire Trinity Basin project. The court held:
We conclude that the Wallisville and Trinity River Projects are not interdependent. The nexus between the projects is not such as to require an EIS evaluation of the Trinity Project as a condition precedent to an EIS evaluation of Wallisville. The Wallis-ville EIS should speak for itself. Wal-lisvlle is a separate viable entity. It should be examined on its own merits. Although it has been made compatible in certain of its features with Trinity it is not a mere component, increment, or first segment of Trinity. The court erred in so holding.
499 F.2d at 990. Faced with a similar situation, the Tenth Circuit reached the same conclusion in Sierra Club v. Stamm, supra. There the plaintiffs attacked the final EIS for the Strawberry Aqueduct and Collection System, a subunit of the larger Bonneville Unit which was in turn a part of the Central Utah Project, because inter alia :
(1) The Statement is too narrow in its scope and should include the cumulative and collective environmental impact of the entire Central Utah Project; (2) the Statement is incomplete in that it is a final statement as *891to the Strawberry Collection System only, and that it should, but does not, encompass all increments of the Bonneville Unit; .
507 F.2d at 790. Relying on Callaway and Armstrong, the court concluded:
In sum, then, we agree with the trial court that the Strawberry system in and of itself constitutes a “major Federal action” and that it is not a mere increment of either the Bonneville Unit or the Central Utah Project requiring a final impact statement for something more than the Strawberry system before work may be commenced on the Currant Creek Dam.
507 F.2d at 792-93. Thus both the Tenth and Fifth Circuits decided cases against the Sierra Club on the same grounds that they assert here.
In its most recent decision on this subject, the Ninth Circuit once again rejected claims that an EIS of larger scope was required by NEPA. The Teton Dam and Reservoir project had been divided into two phases. In Trout Unlimited v. Morton, supra, the plaintiffs argued that the EIS prepared for the initial phase was fatally inadequate because it did not discuss the environmental impact of the Second Phase. After considering the cases relied upon by the majority here,13 the court concluded:
The distinction between those situations in which it has been held that the EIS must cover subsequent phases and that before us is that here the First Phase is substantially independent of the Second while in those in which the EIS must extend beyond the current project, that project was dependent on subsequent phases. The dependency is such that it would be irrational, or at least unwise, to undertake the first phase if subsequent phases were not also undertaken. This is not the case here.
509 F.2d at 1285 (footnote omitted).
The majority attempts to evade the fact that its decision, is contrary to the clear weight of authority elsewhere in the federal courts of the nation by arguing that each of the foregoing decisions involved a “crucial dependence upon the facts.” 14 Obviously all judicial decisions turn on the facts which are presented to the court, but the majority has failed to offer any convincing explanation as to why the facts of the instant case, which present the same situations as the facts in the cases cited above, require a different result.
The regional water projects involved in Callaway, Stamm and Trout Unlimited had certainly progressed to the point where the federal agencies involved had concrete notions as to the ultimate scope of regional development, yet the court in each case found it unnecessary to prepare a regional EIS before acting on the initial phases of the development. In contrast, even if we ignore the statements by the federal appellees that there is at present no overall coordinated program for the development of coal resources in the Northern Great Plains, appellants have failed to establish that planning has progressed to the point where some proposal for major regional federal action exists which could be the subject of a regional EIS.
Furthermore, although there are undoubtedly some interrelationships between development projects along the course of a single river or in a single watershed basin, the Fifth, Ninth and Tenth Circuits were still able to find the projects sufficiently independent to render a more comprehensive EIS unnecessary. The potential development of the Northern Great Plains lacks even this slight relationship between projects. Appellants, at a time of great need for new energy sources, are seeking to halt development of three grades of coal deposits distributed through four states *892and involving nine federal agencies and at least fifteen different forms of “federal action.” Clearly the developments projected for this Region by appellants themselves do not have even the minimal interrelationships one might have expected to find in Callaway, Stamm or Trout Unlimited.
V
The majority is to be credited for perceiving the “practical difficulties” inherent in appellants’ contention that NEPA allows the courts to impose upon the Government the duty to plan comprehensively.15 Truly, such an interpretation could result in the generation of an infinite progression of comprehensive plans which would have to be justified by comprehensive impact statements. It seems obvious that NEPA was enacted as a means of facilitating agency decision making and not as a means of paralyzing the federal government. However, I am concerned. that rather than nipping such fallacious notions in the bud, the majority attempts to demonstrate that appellants’ arguments have a legal basis.16 Although its dicta is constructed on prior dicta and on CEQ Guidelines of questionable force as legal authority, it has laid the groundwork for the perpetuation of this erroneous and impractical position in future cases.
From its review of the record, the majority finds “overwhelming” evidence that “the federal appellees have for years been endeavoring to develop a plan for regional development of the coal resources in the Northern Great Plains.” 17 However, the most remarkable thing about the first two such “endeavors” was the fact that they collapsed without producing any plan for regional development. The only currently pending activity which could lead to the “regional plan” anticipated by the majority is the Northern Great Plains Resources Program Study, but there is no assurance at present that it will be any more successful than the earlier studies. Furthermore, the Study was never intended to produce a comprehensive regional plan for coal development. The Draft Interim Report states:
The primary objective of the Northern Great Plains Resource Program is to provide information and a comprehensive analysis that can be used to place the potential impacts of coal development into perspective and thereby assist the people of the Northern Great plains and the Nation in the management of the natural and human resources of this region.
The three coal development profiles do not represent plans for development, but are instead tools designed to help measure what the effects may be at different rates of development.
Northern Great Plains Resource Program, Draft Report, Sept. 1974, 1 — 4,5 (emphasis in original). Not only is the Study insufficient to be viewed as a regional EIS, as the majority correctly notes,18 its issuance will probably add little to this court’s ability to determine the need for a regional EIS if on remand the federal appellees adhere to their position that they have not yet adopted or proposed a regional development program.
Since review of the record and consideration of those cases which have dealt with claims for the preparation of more “comprehensive” impact statements lead me to agree with the District Court19 that NEPA does not require the preparation of an EIS covering all coal-related development in the entire Northern Great Plains at this time, there is no need to remand this case for further proceedings. Nor is there any justification *893in further delaying projects which are already supported by impact statements through continuation of this court’s temporary injunction.
If appellants believe at some point that an EIS issued in support of federal action on a particular project fails to adequately consider all reasonably related environmental impacts, they can challenge that project under the normal procedure for judicial review of impact statements. Furthermore, in the event the various agencies take concrete steps toward the establishment of a federally coordinated program of regional development, appellants will of course be able to bring their suit if the agencies take a “major federal action” to implement that program without the preparation of the necessary impact statements.20
While the majority’s attempt to force the federal government to engage in comprehensive long-range planning might in some sense be socially “good,” the question before this court is not what the agencies “ought to” do but rather what NEPA requires that they do. To my mind it clearly does not require or authorize the continuance of the temporary injunction to hold federal agencies in check because the majority are suspicious of what the federal agencies might do. I accordingly respectfully dissent.
. Majority Op. 169 U.S.App.D.C. at -, 514 F.2d at 883.
. Id. 169 U.S.App.D.C. at-, 514 F,2d at 883.
. Conclusions of Law, j| 7, App. 247, citing Scientists’ Institute for Pub. Info. v. AEC, 156 U.S.App.D.C. 395, 481 F.2d 1079, 1091 (1973); Natural Resources Defense Council v. Morton, 148 U.S.App.D.C. 5, 458 F.2d 827, 836 (1972); Coalition for Safe Nuclear Power v. AEC, 150 U.S.App.D.C. 118, 463 F.2d 954, 955 (1972); Thermal Ecology Must Be Preserved v. AEC, 139 U.S.App.D.C. 366, 433 F.2d 524, 526 (1970); Gage v. Commonwealth Edison Co., 356 F.Supp. 80, 86 (N.D.Ill.1972); Sherry v. Algonquin Gas, 4 ERC 1713, 1714 (D.Mass. 1972).
. Majority Op. at n. 20.
. Appellants’ argument that it would be “inconvenient” for them to attack specific federal actions does not merit serious consideration by this court.
. The majority asserts:
There has been no contention that any of these individual statements comprehensively study the regional impact of coal development in the Northern Great Plains, and our examination of the statements makes it clear that they do not do so.
Majority Op. at n. 15. However, the real question in this case is whether such a comprehensive study is necessary here. As here indicated, this is merely another form of the inquiry into the sufficiency of statements on individual projects. Since the sufficiency of the individual statements was not litigated before the District Court, if the majority intended this statement as a finding based on its own examination that they are insufficient to support the projects they cover, it would be exceeding the permissible scope of appellate review.
. Appellants’ complaint described the area in issue as “northeastern Wyoming, eastern Montana, western North Dakota and western South Dakota.” App. 2. By a stroke of luck, this vague “region” roughly conformed with the 63 county area which the Northern Great Plains Resources Program (NGPRP) study later identified as the area in which development was likely to occur. However, the conclusion that a region has potential for development is a far cry from a declaration that the federal *886government is undertaking a program of coordinated development of the region. The District Court correctly concluded:
The “Northern Great Plains region” as described by the plaintiffs is not an entity, region, or area which has been defined by the Federal Government by statute or executive action for purposes of any Federal program, project, or action.
Finding of Fact, fl 7, App. 235. Permitting appellants to define their own region for purposes of this action raises the clear possibility that other potential plaintiffs could seek an infinite progression of “regional” statements covering “regions” of their own choice, thus seriously disrupting any attempt by the federal appellees to deal with the development of a critical national resource. The majority recognizes the danger posed by its decision to allow appellants to maintain this action (Majority Op. 169 U.S.App.D.C. at---, 514 F.2d at 874, 875) but declines to give the District Court any guidance on whether it must allow new plaintiffs to maintain suits seeking to compel, for example, the preparation of statements covering all coal deposits in the nation or covering a single Basin in the Northern Great Plains Province, both of which “regions” have also been the subject of various studies. This entire problem could be avoided simply by requiring appellants to challenge a particular federal action, thus enabling the court to evaluate the extent of the environmental impact from that action and define the region accordingly.
. See, e. g., the impact statements prepared for the Westmoreland Resources and Peabody Coal Company mines.
. The Preface to the Final Environmental Impact Statement on the Eastern Powder River Coal Basin, Vol. I, illustrates the considerations used by the federal appellees in determining the necessary scope of an EIS:
Further, to meet the intent of the Act in the most productive fashion, it is necessary to examine the general geographic area of the proposed and potential actions. The geographic area for basic consideration is that part of the Powder River Coal Basin in Wyoming lying generally eastward from the Powder River to the outcrop line of the coal resource and from somewhat north of Gillette to a point somewhat south of Douglas. The area delineation is based in part on present and anticipated levels of mining activity, differing quality of the coal resource, different physical arrangement of the coal beds, somewhat different mining techniques required and differing physical reclamation requirements. Those considerations having a broader scope of geographic impact such as social conditions, economic factors, atmospheric influence, water resources, and recreation uses are treated on a larger regional basis than the primary study area. This statement discusses the existing environment, evaluates the collective impact of the proposed actions and, insofar as now possible, the impacts of potential future coal mining within the geographic area described above. This statement also examines in detail certain proposed activities for which federal actions are required.
. See, e. g., the Final Environmental Impact Statement for the Eastern Powder River Coal Basin, which covers four mines and an associated rail right-of-way. More recently, Interior has released a draft EIS for the Belle Ayr South Mine of the Amax Coal Company, also located in the Eastern Powder River Basin. The Preface to that document states:
In January 1974, the Departments of Interior and Agriculture and the Interstate Commerce Commission decided that, under provisions of Section 102 of the National Environmental Policy Act of 1969, an environmental impact statement must be prepared before any decision could be made on pending proposals for major development of federally-owned coal in the Eastern Powder River Basin of Wyoming. At that time, there were, four major strip mine plans pending approval before the Department of the Interior. There was also pending before the Interstate Commerce Commission proposed construction of a railroad some 113 miles in length, between the Belle Ayr Mine spur southeast of Gillette, Wyoming, and Douglas, Wyoming. This railroad was to serve the coal mines proposed to be developed along the proposed right-of-way in the basin. The construction of this railroad line, the *887four mining proposals, as well as a number of other anticipated or possible future coal-related developments and all their impacts on the environment, were evaluated in an environmental impact statement entitled “Proposed Development of Coal Resources in the Eastern Powder River Basin of Wyoming.” The final statement was filed with the Council on Environmental Quality by the Department of the Interior on October 18, 1974.
Part I of that final environmental impact statement (hereinafter designated FES 74-55) was devoted to a regional analysis encompassing the existing environment, all projected coal development and the cumulative effect of this development on the environment. Parts II through VI of the FES specifically dealt with the four mine plans and the construction of the railroad.
Due to the increased nationwide demand for low sulphur coal for the generation of electricity, it was anticipated that a number of large strip coal mines, in addition to those four mines considered in Parts III through VI of FES 74-55, would also be proposed for development of Federal coal leases in the near future in the Eastern Powder River Coal Basin. Accordingly, the regional analysis of FES 74-55 included data and information from every proposed operation known to be under consideration by the various leaseholders in the study area. In this way the cumulative impacts of the total potential development could be assessed. Subsequent to initiation of preparatory efforts for FES 74-55 and prior to its filing in final form, other proposed mining and reclamation plans for development of existing Federal coal leases in the area were filed for' approval with the Geological Survey, Department of the Interior, as required by law.
Because of the submission date, these plans could not be included for site specific analyses in FES 74-55. In the assessment which follows, the site specific aspects of the proposed mining and reclamation plans for the South Belle Ayr Mine of the Amax Coal Company, are analyzed using information and data previously published in FES 74-55 together with information gained from field observations and company reports. Part I of FES 74-55 is incorporated herein by reference.
. The Ninth Circuit recently arrived at a similar interpretation of SIPI:
Nor is Scientists’ Institute for Public Information v. Atomic Energy Comm’n, 156 U.S.App.D.C. 395, 481 F.2d 1079 (1973) particularly pertinent here. There an EIS was required for continued research and development on the AEC’s Liquified Metal Fast Breeder Reactor (LMFBR) Program covering foreseeable environmental effects if such a reactor were put into future use. The LMFBR has no independent significance absent such future uses. The court was careful to emphasize that its decision to require an EIS was based in large part upon the significance of the overall reactor program as a radical change in the manner in which the entire nation produces electricity. See 481 F.2d at 1089.
Trout Unlimited v. Morton, 509 F.2d 1276, 1285 n. 13 (9th Cir. 1974).
. The Majority Opinion at n. 28 cites two “examples” of how it contends the various present and potential developments are interrelated — the availability of water supplies and manpower resources in the region. Actually, the use of the term “manpower” is a misnomer since what the majority is really talking about is the pressure of the influx of necessary additional manpower on the area. Insofar as one mine creates pressure for a population influx, that is just one more factor to be considered in the EIS for that particular project. However, the opening of that mine in no way commits the agencies to authorizing other mines which would require the importation of additional manpower not already in the area at a future date. With respect to water resources, there is no showing here that the strip mines, which presently are the only projects actively being developed, have sufficient impact on regional water resources to foreclose future alternatives. The proper time to consider such problems will be when the agencies move to a proposed type of development which does tax regional resources. If there is insufficient water for a particular type operation, then that type operation would not be used. In any event, this entire discussion points up the importance of appellants’ failure to show at any point in this record that the EIS on any particular project has failed to adequately consider all relevant environmental impacts.
. The court discussed SIPI and Thompson v. Fugate, 347 F.Supp. 120 (D.Conn.1972) and Indian Lookout Alliance v. Volpe, 345 F.Supp. 1167 (S.D.Iowa 1972), modified, 484 F.2d 11 (8th Cir. 1973). The latter two cases involved attacks on impact statements covering segments of highway and thus presented issues similar to Conservation Society.
. Majority Op. at n. 29.
. Majority Op. 169 U.S.App.D.C. at---, 514 F.2d at 874-875.
. Id. 169 U.S.App.D.C. at---, 514 F.2d at 873-875.
. Id. 169 U.S.App.D.C. at -, 514 F.2d at 875
. Id. 169 U.S.App.D.C. at -, 514 F.2d at 877-878.
. See Conclusions of Law, fl 6, App. 247.
. The majority’s suggestion that the agencies might be required to prepare an impact statement or a statement of reasons to justify why they are not taking major federal action to control development of the Northern Great Plains (Majority Op. 169 U.S.App.D.C. at -, 514 F.2d at 881-882 and n. 37) is clearly not consistent with the provisions of NEPA. Despite the current size of the federal bureaucracy, the realm of things the federal government does not do is still rather large. A good many of these inactions undoubtedly have an impact on the environment, but it is difficult to see how any agency would be able to produce this nearly infinite number of “negative” impact statements and still carry out its assigned functions. In any event, NEPA clearly limits the requirement for preparation of impact statements to “proposals for . . . major federal actions.”