Sure, the site specific analysis that is done when a specific project is proposed is where specific mitigations are applied. But it is the EIS that commits the resource, making it available for leasing, and making it very hard for anyone to challenge any specific leasing decision (that ‘decision was already made in the EIS’ the feds will argue).

As Jason points out one can look at the BLM’s O&G leasing program for a rough correlation. Here we see BLM leasing all sorts of places it shouldn’t: in riparian areas and city watersheds, wildlife refuges, state parks, etc. arguing that it has little choice because a decision has already been made to make these lands (or minerals) for o&g drilling in [insert long-ago year here, such as 1985 for GJ area, 1993 for GMUG forest, etc. etc.]. What BLM is doing–based on its long history with other energy leases and development–is basically punting to itself. THe agency is arguing in a circle, that now it is only looking at ‘big picture’ and ‘programmatic’ issues and that the nitty-gritty will be hashed out in site-specific reviews. Then, when the time comes for site-specific decisions, the agency will (based on historical record) that it has to lease the lands, and that impacts to water, air, land, wildlife, communities, etc. will just have to be ‘mitigated’ even if those impacts are deemed unacceptable to a current (or future) town, state, community, etc.