This is a review of an order of the circuit court for Dane county, P. CHARLES JONES, presiding.
The issue in this case is whether the Wisconsin Environmental Policy Act (WEPA), sec. 1.11, Stats. 1979, requires the Department of Industry, Labor and Human Relations (DILHR), to take environmental factors into account when reviewing the plans of a building project for code compliance. We conclude that, while WEPA requires DILHR to consider environmental factors when promulgating building codes, WEPA does not apply to individual code approval decisions.
In 1978, the James Building Corporation (James) announced plans to build one hundred condominium units in Fish Creek, an unincorporated village in Door Coun*643ty, Wisconsin. The plans provided for a sewage treatment facility which would empty into Green Bay. This system required a number of permits from the Department of Natural Resources, (DNR). DNR prepared an environmental assessment screening worksheet (EASW) on the project and concluded that an environmental impact statement (EIS) was not necessary.
Persons opposed to the project, including some of the respondents in this action, commenced a lawsuit in the Door county circuit court, seeking to have the DNR decision reversed. The Door county circuit court issued a stay ordering DNR to halt all proceedings on the project until it reached a decision on the merits. That stay remains in effect.
On September 8, 1980, James submitted plans to DILHR providing for a 186,750-gallon holding tank as an alternative method of sewage disposal. A holding tank does not treat sewage, but stores it temporarily. Holding tanks must comply with chs. H 62-63, Wis. Adm. Code, but do not require DNR approval.
DILHR initially approved the plans, but, after receiving objections from interested parties including respondents, rescinded its approval since the holding tank was in a flood plain but did not meet the code requirements for holding tanks in flood plains. James submitted new plans, providing for a 250,000-gallon holding tank to be placed outside of the flood plain, on October 21, 1980. Respondents petitioned DILHR for a declaratory ruling that WEPA applied to the code compliance decision and asked for a contested case hearing. DILHR denied these requests on November 11, 1980, and approved James’ plans on November 17,1980.
On December 10, 1980, respondents filed a petition in Dane county circuit court for review of DILHR’s approval of the plans, and on January 6, 1981, filed a motion for a stay of DILHR’s approval of the plans. On January 16, 1981, Dane county circuit court Judge P. Charles Jones granted the stay, halting construction. The cir*644cuit court issued its memorandum decision and order on April 20,1981, holding that WEPA did apply to DILHR’s code compliance review and remanding the case to DILHR for WEPA compliance. DILHR petitioned this court to bypass the court of appeals, sec. 808.05(1), Stats. 1979-80. The petition was granted by this court.
DILHR’s decision not to conduct an environmental inquiry when reviewing the project’s holding tank plans for code compliance was a result of its policy of applying WEPA to its rulemaking process but not to its code compliance review decisions. Interpretation of a statute by an administrative agency is a conclusion of law which may be independently reviewed by the supreme court. Bucyrus-Erie Co. v. ILHR Dept., 90 Wis. 2d 408, 417, 280 N.W.2d 142 (1979). However, the construction and interpretation of a statute by the administrative agency which must apply the law is entitled to great weight and if several rules or applications of rules are equally consistent with the purpose of the statute, the court should defer to the agency’s interpretation. Milwaukee County v. ILHR Dept., 80 Wis. 2d 445, 455-456, 259 N.W.2d 118 (1977). In general, the reviewing court should not upset an administrative agency’s interpretation of a statute if there exists a rational basis for that conclusion. Dairy Equipment Co. v. ILHR Dept., 95 Wis. 2d 319, 327, 290 N.W.2d 330 (1980).
The test as to whether an environmental impact study should be conducted is essentially one of reasonableness and good faith, Wisconsin’s Environmental Decade v. Public Service Commission, 79 Wis. 2d 409, 421-423, 256 N.W.2d 149 (1977). Accordingly, the method by which an administrative agency chooses to comply with WEPA’s mandate that it take environmental factors into account when undertaking its statutory duties should be affirmed if that method is a reasonable one in light of *645the purposes of WEPA and the agency’s functions and duties.
WEPA requires that state agencies review the environmental consequences of decisions which may significantly affect the quality of the human environment.1
*646In 1976, an executive order, entitled Revised Order, Guidelines For The Implementation Of The Wisconsin Environmental Policy Act, Executive Order No. 26 (February 12, 1976), instructed all state agencies to categorize the decisions which they make according to the likelihood that they will require a review of their environmental consequences.
To fulfill WEPA’s mandate, DILHR decided to apply WEPA review, including an EASW and, if necessary, an *647EIS, to the code promulgation process but not to code compliance review.2
DILHR is responsible for the adoption and enforcement of building, heating, electrical, ventilation, air conditioning and plumbing codes.3 Pursuant to secs. 145.01 *648(5) and 145.02, Stats. 1979-80, DILHR is responsible for general supervision of plumbing construction, installation and maintenance.4 Sec. 145.02(3) (d) authorizes *649DILHR to promulgate plumbing codes. When the codes are adopted or revised, DILHR applies the WEPA mandated environmental review process as a part of the rulemaking procedure which it undertakes pursuant to ch. 227, Stats.
Secs. 227.011-227.029, Stats., provide a comprehensive framework for administrative rulemaking. Persons may petition an agency to adopt, repeal or revise a rule.5 Fiscal estimates are prepared,6 and the rule is submitted to the legislative council for form, need and validity.7 Hearings are held,8 for which proper notice must be given9 the conduct of which is governed by statute.10 The proposed rules are then submitted to the legislature 11 and published12 before they go into effect.
The administrative rulemaking procedures seem to parallel the consultation, notice and hearing provision of WEPA.13 Persons or organizations with opinions as to the environmental effect of a rule can make their views known to the rulemaking body, and the ch. 227 procedure *650provides a framework for a comprehensive consideration of environmental factors.
Assuming, without deciding, that DILHR has authority to apply WEPA considerations to code compliance reviews,14 the question is: Has DILHR complied with WEPA in applying its provisions only to its code promulgation functions. DILHR has in effect focused its environmental review on the program or policy level rather than the specific project level. This mode of analysis provides for review, on a broad scale, of agency decisions which individually might be overlooked as environmentally insignificant.15 It also assures that environmental considerations are taken into account before significant resources are expended on a project.
We conclude WEPA does not compel DILHR, which has complied with WEPA in the rulemaking process, to also apply WEPA review to code compliance decisions. Building codes are contained in Chs. INd. 50-64 and H 62-63, Wis. Adm. Code. They contain detailed and comprehensive specifications which must be adhered to before a permit may be issued.. Sec. INd. 50.14 provides for an interim permit to start construction, which may be issued by the department upon submission, but prior to approval, of the plans. While someone who starts construction based upon the interim permit runs the risk that the department may not approve the plans, this risk is minimized by the specificity of the codes, which enable the builder who has diligently incorporated the code provisions into his plans to start work, confident that the plans will be approved.
*651DILHR has estimated that it makes around 12,000-code compliance decisions a year. Respondents did not take issue with this assessment. Review on such a scale is possible because of the detail of the codes. The straight forward and nondiscretionary process by which plans are reviewed for code compliance was commented on by this court in Dunn v. State, 125 Wis. 181, 190-191, 102 N.W. 935 (1905) :
“It is clear from the uncontradicted facts in evidence that the application by the Pabst Brewing Company for a permit to erect this bottling house involved no exercise of any discretion by the accused as building inspector. He informed Mr. Pabst, and insisted upon the trial, that he could not grant the permit applied for, because the plans and specifications obviously violated the building regulations of the city, in that the floor areas within the specified walls were largely in excess of what was permitted and allowed by such regulations; nor does the plaintiff in error dispute or claim but that such was the fact, and that no permit could properly be granted to build the structure pursuant to the plans and specifications submitted. Under these facts and circumstances it is apparent that no question of discretion arose in passing upon the application for a permit to erect this building, . . .”
Other jurisdictions have held that a person who is refused a building or plumbing permit is entitled to a writ of mandamus compelling the issuance of the permit if he shows that the project complied with applicable codes.16 This reflects the role of codes as detailed norms which a builder must incorporate into a project rather than as nebulous indicators of social policy to guide a *652quasi-adjudicative decision maker in determining the worth of a building project.
Incorporation of social policy values by DILHR, such as those reflected in WEPA, is here done by code promulgation rather than code compliance review. This policy is reflected by Sections INd. 50.21-22, Wis. Adm. Code (1980),17 wherein DILHR has delegated code compliance review to certain municipalities. WEPA by its terms applies only to decisions by state agencies. Local deci*653sions are outside of its scope. If WEPA were interpreted to apply to the code compliance review process, applicants for building permits in the municipalities to whom DILHR delegated code review, would not be subjected to its provisions.18 This would defeat the statewide uniformity goal underlying the state building code,19 and envisioned in the Environmental Policy Act. In contrast to code compliance review, all code promulgation is done at the statewide level and consideration of WEPA at this level would not undermine uniformity.
DILHR’s application of WEPA to code promulgation and not to code compliance review is consistent with prior interpretations of WEPA. In Wisconsin’s Environmental Decade, supra, we held that WEPA did not require one specific mode of compliance and that program wide, or generic, impact statements were not merely acceptable, but may be preferable in certain situations.
“[W]e are not insensitive to the possibility that the environmental issues may in fact be complex and that a comprehensive consideration of these issues might consume considerable time. We have indicated that the *654obligations imposed by sec. 1.11, Stats., are not inherently discretionary or flexible. However, we think an agency possesses a reasonable amount of discretion as to the precise mode by which compliance is effected. We think such discretion includes the Commission’s developing a generic or ‘programmatic’ EIS for rate proceedings. Indeed, the case-by-case or project-by-project approach to the threshold question of whether an EIS is required may in certain areas be too limited.” Wisconsin’s Environmental Decade, supra, 79 Wis. 2d at 439.
Agency discretion in its mode of WEPA compliance was emphasized in Holtz & Krause, Inc. v. DNR, 85 Wis. 2d 198, 215, 270 N.W.2d 409 (1978), in which this court found no WEPA violation where DNR conducted an inquiry which was the “functional equivalent” of an EIS.
We hold that DILHR in applying WEPA to its code promulgation function and not to individual code compliance review conforms to the requirements of the Environmental Policy Act. We conclude that DILHR was not in violation of that act in approving the sewage holding tank at issue here.
By the Court. — Order reversed and cause remanded with directions to dismiss the complaint.
Abrahamson, J., took no part.“1.11. Governmental consideration of environmental impact. The legislature authorizes and directs that, to the fullest extent possible :
“(1) The policies and regulations shall be interpreted and administered in accordance with the policies set forth in this section and chapter 274, laws of 1971, section 1; and
“(2) Except as provided in s. 145.022, all agencies of the state shall:
“(c) Include in every recommendation or report on proposals for legislation and other major actions significantly affecting the quality of the human environment, a detailed statement, substantially following the guidelines issued by the United States council on environmental quality under P.L. 91-190, 42 U.S.C. 4331, by the responsible official on:
“1. The environmental impact of the proposed action;
“2. Any adverse environmental effects which cannot be avoided should the proposal be implemented;
“3. Alternatives to the proposed action;
“4. The relationship between local short-term use of man’s environment and the maintenance and enhancement of long-term productivity; and
“5. Any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented ;
“6. Such statement shall also contain details of the benefit aspects of the proposed project, both short term and long term, and the economic advantages and disadvantages of the proposal.
“(d) Prior to making any detailed statement, the responsible official shall consult with and obtain the comments of any agency which has jurisdiction or special expertise with respect to any environmental impact involved. Copies of such statement and the comments and views of the appropriate agencies, which are authorized to develop and enforce environmental standards shall be made available to the governor, the department of natural resources and to the public. Every proposal other than for legislation shall receive a public hearing before a final decision is made. Holding a public hearing as required by another statute fulfills this section. If no public hearing is otherwise required, the respon*646sible agency shall hold the hearing in the area affected. Notice of the hearing shall be given by publishing a class 1 notice, under ch. 986, at least 16 days prior to the hearing in a newspaper covering the affected area. If the proposal has state-wide significance, notice shall be published in the official state newspaper;
“(e) Study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources ;
“(h) Initiate and utilize ecological information in the planning and development of resource-oriented projects.
“(3) All state agencies shall review their present statutory authority, administrative regulations, and current policies and procedures for the purpose of determining whether there are any deficiencies or inconsistencies therein which prohibit full compliance with the purposes and provisions of this section and chapter 274, laws of 1971, section 1 and shall propose to the governor not later than July 1, 1972, such measures as may be necessary to bring their authority and policies into conformity with the intent, purposes, and procedures set forth in this section and chapter 274, laws of 1971, section 1.
“(4) Nothing in this section affects the specific statutory obligations of any agency;
“(a) To comply with criteria or standards of environmental quality;
“(b) To coordinate or consult with any other state or federal agency; or
“(c) To act, or refrain from acting contingent upon the recommendations or certification of any other state or federal agency.
“(6) The policies and goals set forth in this section are supplementary to those set forth in existing authorization of agencies.”
DILHR reviews approximately 12,000-building permits per year. When the legislature passed WEPA, it provided no additional appropriations to state agencies to fulfill their WEPA functions. Subsequent attempts by agencies to get funding for WEPA duties have also proved unsuccessful. See J. Hanson, Agency De-cisionmaking Under The Wisconsin Environmental Policy Act, 1977 Wis. L. Rev. Ill, 126-128, 159-161.
DILHR asserted, and respondents did not dispute, that WEPA was applied to its promulgation of building codes. EASWs concerning the plumbing codes which apply to holding tanks were prepared by DILHR on June 9, 1980, concerning ch. H 63, Wis. Adm. Code (1980) and by DH&SS on September 19, 1975, concerning sec. H 62.20, Wis. Adm. Code (1975).
“101.02. Powers, duties and jurisdiction of department. It shall be the duty of the department, and it shall have power, jurisdiction and authority:
“(1) To adopt reasonable and proper rules and regulations relative to the exercise of its powers and authorities and proper rules to govern its proceedings and to regulate the mode and manner of all investigations and hearings. . . .
“(15) (a) The department has such supervision of every employment, place of employment and public building in this state as is necessary adequately to enforce and administer all laws and all lawful orders requiring such employment, place of employment or public building to be safe, and requiring the protection of the life, health, safety and welfare of every employe in such- employment or place of employment and every frequenter of such place of employment and the safety of the public or tenants in any such public building. . . .
“(j) To ascertain, fix and order such reasonable standards, rules or regulations for the construction, repair and maintenance of places of employment and public buildings, as shall render them safe.”
“101.12 Approval and inspection of public buildings and places of employment and components. (1) The department shall require the submission of essential drawings, calculations and specifications for public buildings, public structures and places of employment. . .
*648“(2) Plans of said buildings, structures and components shall be examined for compliance with the rules of the department and a statement of the examination returned to the designer and owner before construction is started. Nothing in this section shall relieve the designer of the responsibility for designing a safe building, structure or component.”
“145.13 Promulgation of plumbers’ code. The state plumbing code and amendments thereto as adopted by the department have the effect of law in the form of standards state-wide in application and shall apply to all types of buildings, private or public, rural or urban, including buildings owned by the state or any political subdivision thereof. All plumbing installations shall so far as practicable be made to conform with such code.”
The building, heating, ventilation and air-conditioning codes are in Chs. Ind. E. 50-64, Wis. Admin. Code. The electrical code is in Chs. sec. .1-145, Wis. Admin. Code and the plumbing code is contained in Chs. H 62-63, Wis. Admin. Code.
“145.01. Definitions. ... (5) Department. ‘Department’ means the department of industry, labor and human relations.”
“145.02. Powers of department. (1) The construction, installation and maintenance of plumbing in connection with all buildings in this state, including buildings owned by the state or any political subdivision thereof, shall be safe, sanitary and such as to safeguard the public health.
“(2) The department shall have general supervision of all such plumbing and shall after public hearing prescribe and publish and enforce reasonable standards therefor which shall be uniform and of state-wide concern so far as practicable. Any employe designated by the department may act for the department in holding such public hearing.
“(3) The department may exercise such powers as are reasonably necessary to carry out the provisions of this chapter. It may, among other things: . . .
“(d) Prepare and cause to be printed such codes, bulletins or other documents as may be necessary and furnish copies thereof to those engaged in the plumbing business and to the public upon request. . . .
“(f) Issue special orders directing and requiring compliance with the rules and standards of the department promulgated under this chapter whenever, in the judgment of the department, the rules or standards are threatened with violation, are being vio*649lated or have been violated. The circuit court for any county where violation of such an order occurs has jurisdiction to enforce the order by injunctive and other appropriate relief. The attorney general or the district attorney of the county where the violation of the order occurs shall bring action for its enforcement. The department may issue an order under this paragraph to abate a violation of s. 146.13 or 146.14.
“(g) By rule, fix fees for the examination and approval of plans of plumbing systems and collect the same.”
Prior to April 29, 1980, the effective date of ch. 221, Laws of 1979, functions relating to the plumbing code rested with the Department of Health and Social Services, (DH&SS), see ch. 221, section 643, Laws of 1979.
Section 227.015, Stats. 1979-80.
Section 227.019, Stats. 1979-80.
Section 227.029, Stats. 1979-80.
Section 227.02, Stats. 1979-80.
Section 227.021, Stats. 1979-80.
Section 227.022, Stats. 1979-80.
Section 227.018, Stats. 1979-80.
Section 227.025, Stats. 1979-80.
See section 1.11(2) (d), Stats. 1979-80.
Such authority would seem to be inconsistent with the legislative authorization for DILHR to delegate code compliance review function to local units of government, which are not subject to WEPA. See discussion of this matter, infra, in this opinion.
See J. Hanson, Agency Decisions Under WEPA, 1977 Wis. L. Rev. Ill, 166-179, which advocates an increased use of program-wide rather than specific project WEPA review.
Munns v. Stenman, 152 Cal. App. 2d 543, 314 P.2d 67, 76 (1957); Timko v. Chotkowski, 26 Conn. Supp. 266, 220 A.2d 286, 289 (1966); State Dept. of Health v. Walker, 238 Md. 512, 209 A.2d 555, 561 (1965); Fellsway Realty Corp. v. Building Comr. of Medford, 332 Mass. 471, 125 N.E.2d 791 (1955); Berry v. Embrey, 238 Miss. 819, 120 So. 2d 165, 168 (1960); Vagnoni v. Brady, 420 Pa. 411, 218 A.2d 235, 237 (1976). See generally, 101A C.J.S., Zoning and Land Planning, Section 295b (1979); 9 McQuillin, Law of Municipal Corporations (3rd ed.), Sections 26.206, 26.221 (1978).
“INd. 60.21 First class city examination and approval. Drawings, specifications and calculations for all buildings and structures, except state-owned buildings and structures, to be constructed within the city limits of Milwaukee shall be submitted to the inspector of buildings, Milwaukee, for examination and approval.”
“INd. 50.22 Certified cities examination and approval. Drawings, specifications and calculations for all new buildings and structures containing less than 50,000 cubic feet total volume and alterations to buildings containing less than 100,000 cubic feet total volume, except state-owned buildings and structures, shall be submitted to cities certified by the department for examination and approval according to requirements of this code. Drawings, specifications and calculations submitted to said cities for examination and approval need not be submitted to the department. The buildings must be located within the city limits of the certified city.”
DILHR’s authority to delegate this function is provided for by Sec. 101.12(3) (a) and (b), Stats. 1979, which reads:
“101.12. Approval and inspection of public buildings and places of employment and components. ... (3) The department shall:
“(a) Accept the examination of essential drawings, calculations and specifications in accordance with sub. (1) performed by cities of the 1st class provided the same are examined in a manner approved by the department.
“(b) Accept the examination of essential drawings, calculations and specifications in accordance with sub. (1) for buildings containing less than 50,000 cubic feet of volume and alterations to buildings containing less than 100,000 cubic feet of volume performed by cities of the 2nd and 3rd class provided the same are examined in a manner approved by the department. The department shall determine and certify the competency of all such examiners.”
Section H 65.25(2) (d), Wis. Admin. Code (1979), provides for a similar delegation of plumbing code compliance review.
The plumbing code, See. H 63.18(2), Wis. Adm. Code (1980), permits local units of government to prohibit construction of any holding tanks within their boundaries.
“H 63.18 Holding tanks. ... (2) PROHIBITING holding tanks. Holding tanks for new construction may be prohibited by county ordinance. If the county allows the use of holding tanks for new construction, then such use may be prohibited by city, village, or town ordinance. If a governmental unit prohibits holding tanks for new construction, then the governmental unit shall provide an appeal procedure to this prohibition. The county board, city council, village board or town board or the designated committee of such governmental unit, may grant variances to their holding tank prohibition. The county, city, village or town shall inform the department in writing of each variance.”
See, Note: Building Codes: Reducing Diversity And Facilitating The Amending Process, 5 Harv. J. Legis. 587 (1968) for discussion of the benefits of statewide, rather than local, building codes.