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4 42 U.S.C. § 4321. 5 Id. § 4332(2)(C). 6 Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 350 (1989). 7 Id. (quoting Kleppe v. Sierra Club, 427 U.S. 390, 410 n.21 (1976)). 8 The CEQ reports that, across all federal agencies, completion time for an Environmental Impact Statement (EIS)-from issuance of a notice of intent to prepare an EIS through publication of a record of decision-took an average (mean) of 4.5 years and a median of 3.6 years. One quarter of EISs took less than 2.2 years to complete, and one quarter took more than 6.0 years to complete. EXEC. OFFICE OF THE PRESIDENT, COUNCIL ON

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