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MEMORANDUM OPINION BULLOCK, District Judge. This action began on February 18, 1999, when Plaintiffs, North Carolina Alliance for Transportation Reform, Inc. and Friends of Forsyth County, filed a complaint against the United States Department of Transportation (“USDOT”); Rodney E. Slater, the Secretary of USDOT; the Federal Highway Administration (“FHWA”); Kenneth R. Wykle, the Administrator of FHWA; and Nicholas L. Graf, the Division Administrator of FHWA (collectively “Federal Defendants”). Also named in the complaint were the North Carolina Department of Transportation (“NCDOT”) and E. Norris Tolson, the Secretary of NCDOT (collectively “State Defendants” and collectively with Federal Defendants “Defendants”). In the complaint, Plaintiffs alleged that the construction of the Western Section of the Winston-Salem Northern Beltway (the ‘Western Section”) violated the National Environmental Policy Act (“NEPA”), 42 U.S.C. § 4321 et seq. and the North Carolina Environmental Policy Act (“NCE-PA”), N.C. Gen.Stat. § 113A-1 et seq. On June 21, 1999, the parties filed a joint motion for an order of dismissal. The court entered an order of dismissal on June 29, 1999. Now pending before the court is Plaintiffs’ motion for an award of attorney’s fees and expenses. For the following reasons, the court will grant Plaintiffs’ motion. BACKGROUND In 1989, the North Carolina General Assembly passed the North Carolina Highway Trust Fund (the “Trust Fund”). The Trust Fund designated seven urban areas around which highway loops would be constructed. Winston-Salem, North Carolina was one of the urban areas designated by the Trust Fund. The construction of the Winston-Salem Northern Beltway was the subject of the litigation giving rise to this claim for attorney’s fees and expenses. On June 24, 1992, NCDOT published a draft environmental impact statement (“DEIS”) for the Western Section. On March 29, 1996, NCDOT published the final environmental impact statement (“FEIS”). On May 6, 1996, the Raleigh Division of FHWA submitted the record of decision (“ROD”) to FHWA’s Regional Administrator for approval of the project. One day later, on May 7, 1996, FHWA’s Regional Administrator issued the ROD. Issuance of the ROD represented final agency action on the Western Section project and completed the NEPA process. By issuing the ROD, Federal Defendants effectively approved the project and accepted the environmental impact statement prepared for the project. The day after issuance of the ROD, May 8, 1996, FHWA announced that the Transportation Improvement Program for the Winston-Salem metropolitan area (“Forsyth County’s TIP”) no longer conformed with the requirements of the Clean Air Act. As a result, federal agencies could neither approve nor fund any Forsyth County transportation projects that had not already completed the NEPA process. Under a regulatory provision in place at the time, however, funding for the Western Section was permitted to continue because the NEPA process had been completed (the ROD had been issued) before Forsyth County’s TIP fell out of conformity with the Clean Air Act. On October 2, 1996, Forsyth County’s TIP was found again to conform with the Clean Air Act. On February 18, 1999, Plaintiffs filed a complaint alleging that the final environmental impact statement prepared for the Western Section was inadequate and violated NEPA and NCEPA. In their complaint, Plaintiffs sought: 1) a declaratory judgment that Defendants violated NEPA and NCEPA; 2) a mandatory injunction directing Defendants to comply with the provisions of NEPA and NCEPA; 3) an order vacating the May 7, 1996, record of decision which approved the final environmental impact statement and construction of the proposed beltway; 4) and an injunction prohibiting defendants from proceeding with site preparation, construction, the issuance of revenue bonds, right of way acquisitions, or any other irrevocable actions related to the building of the proposed Beltway until the violations of NEPA and NCEPA had been corrected. {See Pis’. Compl. [Doc. # 1] at ¶ 4). On March 2, 1999, the Court of Appeals for the District of Columbia Circuit decided Environmental Def. Fund v. EPA, 167 F.3d 641 (D.C.Cir.1999) [hereinafter EDF] In that case, the court struck down certain EPA regulations. Among the regulations struck down was 40 C.F.R. § 93.102(c), known as the “grandfather” rule, which allowed projects to receive federal funding in the absence of a currently conforming TIP as long as the project was part of a conforming plan at the time of its approval. See EDF, 167 F.3d at 649. The EDF Court held that the grandfather rule violated the Clean Air Act and that only projects located in an area with a currently conforming TIP were eligible to receive federal funds. Id. On April 4, 1999, the TIP for Forsyth County again lapsed into non-conformity with the Clean Air Act. Due to the ruling in EDF, Forsyth County’s lapse of conformity meant that the Western Section could not receive any federal funds until the TIP was again brought into conformity with the Clean Air Act. On April 15, 1999, Nicholas Graf (“Graf’), the Administrator of the North Carolina Division of FHWA, notified NCDOT that FHWA had decided to “reopen the NEPA process to consider whether new or supplemental analysis and documentation are warranted on the [Western Section] project.” (Fed. Defs.’ Mem. in Supp. of Mot. to Dismiss [Doc. # 10], Ex. A-l). This decision to reopen the NEPA process was made “because of’ the lawsuit instituted by Plaintiffs, the EDF decision, and Forsyth County’s April 4, 1999, lapse into non-conformity with the Clean Air Act. Id. By reopening the NEPA process FHWA effectively withdrew the previously issued ROD. With the reopening of the NEPA process, Plaintiffs’ action to enjoin Defendants became moot. On June 21, 1999, the parties filed a joint motion for an order of dismissal. The court entered an order of dismissal on June 29,1999. Thereafter, on August 27, 1999, Plaintiffs filed this motion for an award of attorney’s fees and expenses. In a previous opinion related to Plaintiffs’ motion for attorney’s fees and expenses, this court concluded that the motion is properly before the court for consideration. See North Carolina Alliance for Transp. Reform, Inc. v. United States Dep’t of Transp., 104 F.Supp.2d 599 (M.D.N.C.2000). Plaintiffs seek attorney’s fees and expenses from Federal Defendants under Sections 2412(b) and 2412(d) of the Equal Access to Justice Act (“EAJA”) and from State Defendants under Section 6-19.1 of the North Carolina General Statutes (“N.C.G.S. § 6-19.1”). ANALYSIS I. Prevailing Party Status Each of the statutes under which Plaintiffs seek attorney’s fees and expenses provides that such an award is available only if Plaintiffs are found to be “prevailing” See 28 U.S.C. § 2412(b), (d); N.C. Gen.Stat. § 6-19.1. Plaintiffs satisfy this requirement. The party seeking attorney’s fees bears the burden of proving that it was the prevailing party. See Reich v. King Plumbing & Heating Contractor, Inc., 98 F.3d 147, 150 (4th Cir. 1996); see also House v. Hillhaven, Inc., 105 N.C.App. 191, 195-96, 412 S.E.2d 893, 896 (1992). In their complaint filed February 18, 1999, Plaintiffs sought: (1) a declaratory judgment that Defendants violated NEPA and NCEPA; (2) a mandatory injunction directing Defendants to comply with the provisions of NEPA and NCEPA; (3) an order vacating the May 7, 1996, record of decision which approved the final environmental impact statement and construction of the proposed beltway; and (4) an injunction prohibiting Defendants from proceeding with site preparation, construction, the issuance of revenue bonds, right of way acquisitions, or any other irrevocable actions related to the building of the proposed Western Section until the violations of NEPA and NCEPA had been corrected. (Pis.’ Compl. [Doc. # 1] at ¶ 4). On April 15, 1999, the FHWA sent a letter to NCDOT which stated, in relevant part: Dear Secretary Tolson: As you know, the recent lawsuit filed in the United States District Court for the Middle District of North Carolina alleged deficiencies in the Final Environmental Impact Statement (FEIS) for the Western Section of the Winston-Salem Bypass.... The Winston-Salem Bypass project was included in the Long Range Transportation Plan (LRTP) and Transportation Improvement Program (TIP) for the Winston-Salem metropolitan area. That plan and program previously demonstrated conformity under the Clean Air Act. However, on April 4, 1999, the Winston-Salem metropolitan area lapsed conformity and does not currently have a conforming LRTP and TIP. ... In accordance with [.Environmental Def. Fund v. EPA, 167 F.3d 641 (D.C.Cir.1999) ], we are prohibited from approving further activities on the Western Section of the Winston-Salem Bypass until a new conformity finding is made on an updated LRTP and TIP. Because of these developments, I have decided to reopen the NEPA process to consider whether new or supplemental analysis and documentation are warranted on the Winston-Salem Bypass project— Therefore, we will not grant further approvals on the Winston-Salem Bypass project until after we have completed any new or supplemental environmental analysis and documentation; the Bypass project has come from a currently conforming LRTP and TIP for the Winston-Salem metropolitan area; and we have made a new final decision to proceed with the project. (Federal Defs.’ Mem. in Supp. of Mot. to Dismiss [Doc. # 10], Ex. A-l)(emphasis added). On June 21,1999, the parties filed a joint motion to dismiss pursuant to Rule 41(a)(2) of the-Federal Rules of Civil Procedure. On June 29, 1999, this court issued its Order of Dismissal, which stated, in relevant part: 1. Plaintiffs complaint is dismissed without prejudice; 2. The Court determines, based on the representations of the federal defendants, that the final agency action which was challenged in this case has been superseded and therefore shall no longer be relied upon for any actions by defendants; 3. Federal defendants shall not grant any further approvals, enter into any contracts, or provide any funds relating to the acquisition of property or construction of the Western Section of the Winston-Salem Beltway (hereafter “Bypass Project”) until the new environmental analysis and documentation process has been completed, a conforming Long Range Transportation Plan and Transportation Improvement Program for the Winston-Salem metropolitan area have been approved, and federal defendants issue a new Record of Decision pursuant to applicable federal law for the Bypass Project; 4. State defendants shall not take any irrevocable actions relating to construction, right-of-way acquisitions, or negotiations for right-of-way acquisitions, in furtherance of the Bypass Project until the conditions set forth in paragraph 3 above have been met. North Carolina Alliance for Transp. Reform v. United States Dep’t. of Transp., No. 99CV134 (M.D.N.C. June 29, 1999) (Order of Dismissal, [Doc. # 21]). In Hensley v. Eckerhart, 461 U.S. 424, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983), a case brought pursuant to 42 U.S.C. § 1988, the Supreme Court defined a “prevailing party” as one who succeeded “on any significant issue in litigation which achieves some of the benefit the parties sought in bringing suit.” Id. at 433, 103 S.Ct. 1933. In Farrar v. Hobby, 506 U.S. 103, 113 S.Ct. 566, 121 L.Ed.2d 494 (1992), another case for attorney’s fees under 42 U.S.C. § 1988, the Supreme Court further clarified prevailing party status: [T]o qualify as a prevailing party, a civil rights plaintiff must obtain at least some relief on the merits of his claim. The plaintiff must obtain an enforceable judgment against the defendant from whom fees are sought, or comparable relief through a consent decree or settlement. Whatever relief the plaintiff secures must directly benefit him at the time of the judgment or settlement. Otherwise the judgment or settlement cannot be said to “affec[t] the behavior of the defendant toward the plaintiff.” Farrar, 506 U.S. at 111, 113 S.Ct. 566 (internal citations omitted). In S-l and S-2 By and Through P-1 and P-2 v. State Bd. of Educ. of North Carolina, 6 F.3d 160 (4th Cir.1993) (Wilkinson, J., dissenting), adopted as majoñty opinion, 21 F.3d 49 (4th Cir.1994) (en banc), the Fourth Circuit interpreted Farrar as rejecting the “catalyst theory” when determining prevailing party status under 42 U.S.C. § 1988. The Fourth Circuit held that “[t]here is no way ... that Farrar and a broad ‘catalyst theory’ of attorneys’ fees recovery can be recon-died.” S-l and S-2, 6 F.3d at 168-69. Rather, the Fourth Circuit concluded that to be deemed a prevailing party, a party seeking attorney’s fees “must succeed on the merits of a claim.” Id. at 170. According to the Fourth Circuit, the determinative factor in finding a plaintiff to be a prevailing party is whether a “material alteration of the legal relationship between the parties” entitles the plaintiff to enforce “a judgment, consent decree, or settlement against the defendant.” Id. “In other words, success must be something buttressed by a court’s authority.” Id. As indicated in the April 15, 1999, letter from FHWA to NCDOT, the lawsuit brought by Plaintiffs was a factor contributing to Defendants decision to withdraw the record of decision. This point is also clearly made in an internal memorandum drafted by an engineer with the North Carolina Department of Transportation, which states in part: NCDOT is currently re-evaluating the Environmental Impact Statement (EIS) for R-2247 (Western Section of the Winston-Salem Beltway, from U.S. 158 to U.S. 52). As a result of the lawsuit filed against NCDOT by Friends of Forsyth and N.C. Alliance for Transportation Reform, FHWA rescinded the Record of Decision. (Pis.’ Mem. in Opp’n to Fed. Defs.’ Mem. Regarding Substantial Justification [Doc. # 63], Ex. 1 at 2)(emphasis added). The memorandum also states that “[t]he purpose of the re-evaluation is two-fold: (1) to address the alleged deficiencies of the EIS as outlined in the lawsuit, and (2) to determine if there exists any reasonable and feasible alternatives that were not evaluated in the EIS.” Id. In addition to this evidence that the lawsuit brought by Plaintiffs played a significant part in Defendants’ decision to reopen the environmental analysis process, the Order of Dismissal issued by this court granted Plaintiffs a substantial portion of the relief they requested in their complaint. Specifically, the Order of Dismissal, which Plaintiffs were entitled to enforce against Defendants, precluded Defendants from granting any further approvals, entering into any contracts, or providing any funds relating to the acquisition of property or construction of the Western Section until the new environmental analysis and documentation process had been completed. (Order of Dismissal, [Doc. #21] at ¶¶ 3, 4). The Order of Dismissal embodies a significant portion of the relief Plaintiffs sought in filing the civil action in the first place. Therefore, Plaintiffs are prevailing parties. Having found Plaintiffs to be prevailing, the court must consider the other requirements of the various statutes under which Plaintiffs seek fees and expenses. II. 28 U.S.C. § 2112(b) Plaintiffs seek attorney’s fees and expenses from Federal Defendants under Section 2412(b) of the Equal Access to Justice Act. This Section provides in part that: Unless expressly prohibited by statute, a court may award reasonable fees and expenses of attorneys ... to the prevailing party in any civil action brought by or against the United States or any agency.... The United States shall be hable for such fees and expenses to the same extent that any other party would be liable under the common law or under the terms of any statute which specifically provides for such an award. 28 U.S.C. § 2412(b). The Fourth Circuit has interpreted § 2412(b) to allow an award of fees and expenses in cases where the government has acted in bad faith. See, e.g., Hyatt v. Shalala, 6 F.3d 250, 254 (4th Cir.1993); Sullivan v. Sullivan, 958 F.2d 574, 577 n. 8 (4th Cir.1992). A finding of bad faith is a factual determination within the discretion of the district court. See Hyatt, 6 F.3d at 255. The burden is on the plaintiff to show bad faith conduct by the defendant. United States v. Ford, 737 F.2d 1506, 1510 (9th Cir.1984). Bad faith conduct may be found when an agency “confronted with a clear statutory or judicially-imposed duty towards another, is so recalcitrant in performing that duty that the injured party is forced to undertake otherwise unnecessary litigation to vindicate plain legal rights.” American Hosp. Ass’n v. Sullivan, 938 F.2d 216, 220 (D.C.Cir.1991) (citations omitted). Plaintiffs claim that Federal Defendants acted in bad faith by issuing an ROD for a project that Federal Defendants knew to have an inadequate final environmental impact statement. According to Plaintiffs, two factors provide evidence that Federal Defendants’ knew that the FEIS for the Western Section was inadequate at the time the record of decision issued: the short time between submission and issuance of the ROD and FHWA’s eventual decision to re-open the entire NEPA process rather than re-opening only the air quality analysis. FHWA’s Regional Administrator issued the record of decision only one day after its submission. The Raleigh Division of FHWA submitted the ROD to the FHWA Regional Administrator on May 6, 1996. The Regional Administrator issued the ROD on May 7, 1996. Plaintiffs contend that by considering the ROD for only one day Federal Defendants inadequately reviewed the Western Section’s environmental analysis before granting approval of the project. According to Plaintiffs, the one-day consideration of the ROD alone constitutes a procedural violation of NEPA and amounts to bad-faith conduct on the part of Federal Defendants. This is not the only evidence of FHWA’s inadequate consideration of the environmental analysis for the Western Section, though. The issuance of the ROD came one day prior to FHWA’s announcement on May 8, 1996, that Forsyth County’s TIP no longer conformed with Clean Air Act requirements. Under regulatory provisions applicable at the time, a project located in an area in conformity with the Clean Air Act when the project was approved could continue to receive federal funds even if the area subsequently fell out of conformity with the Clean Air Act. Therefore, by issuing the ROD prior to the announcement of nonconformity, Federal Defendants ensured that the Western Section project would be eligible to receive funding even though Forsyth County was to fall into non-conformity with the Clean Air Act the very next day. Plaintiffs argue that “[i]t is inconceivable that FHWA was not aware of the impending announcement of nonconformity on May 7, 1996, the day it approved the ROD.” (Pis.’ Mem. in Supp. of Their Mot. for an Award of Attys.’ Fees and Expenses [Doc. #25] at 7). Plaintiffs further contend that the sequence of events, submission of the ROD on May 6, issuance of the ROD on May 7, and announcement of non-conformity on May 8, inexorably leads to the conclusion that Federal Defendants rushed the issuance of the ROD in an attempt to avoid the funding freeze that would commence upon the announcement of non-conformity. In hurrying through the approval process, Plaintiffs claim that Federal Defendants issued an ROD for a project that Federal Defendants knew to have serious flaws in its final environmental impact statement. Plaintiffs also argue that Federal Defendants’ decision to reopen the entire NEPA process in April 1999 was an implicit admission that the environmental impact statement for the Western Section was inadequate at the time the ROD originally issued. Plaintiffs contend that the only aspect of the environmental impact statement that could have changed significantly between the initial issuance of the ROD in May 1996 and the reopening of the NEPA process in April 1999 was the air quality analysis. Nevertheless, when Federal Defendants reopened the NEPÁ process in April 1999, they opted to review the entire environmental analysis rather than focusing only on the air quality analysis. Federal Defendants dispute Plaintiffs’ characterization of the events surrounding the issuance of the ROD. Federal Defendants argue that FHWA had “extensive involvement” throughout the NEPA process. (Fed. Defs.’ Reply Mem. Regarding the Issue of Substantial Justification [Doc. # 65] at 6). According to Federal Defendants, FHWA and NCDOT worked together over a matter of years to prepare the FEIS for the Western Section. Consequently, Federal Defendants argue that at the time the Raleigh Division of FHWA submitted the ROD to the FHWA regional administrator, the agency was already familiar with the environmental analysis that had been undertaken. Federal Defendants also contend that “[ajbsent significant adverse comments, the decision maker, who has been intimately involved in the NEPA process, can approve the ROD without further extensive deliberation beyond that which has already occurred.” (Fed. Defs.’ Reply Mem. Regarding the Issue of Substantial Justification [Doc. # 65] at 5-6). Other than general claims of participation, Federal Defendants have provided the court with no specific information as to the part they played in preparing the FEIS. In addition, according to Federal Defendants’ position regarding the Regional Administrator’s role in issuing the ROD, review of the ROD and final agency action on a project is essentially a perfunctory matter unless there are “significant adverse comments.” (Fed. Defs.’ Reply Mem. Regarding the Issue of Substantial Justification [Doc. # 65] at 6). Federal Defendants cite no authority for this proposition. Even if it were correct, however, Federal Defendants’ own brief indicates that such an expedited consideration of the ROD would not have been undertaken in good faith in this case. According to Federal Defendants, “[n]umerous comments were received” in response to the FEIS. (Fed. Defs.’ Reply Mem. Regarding the Issue of Substantial Justification [Doc. # 65] at 6). Despite these numerous comments, FHWA’s Regional Administrator issued the ROD only one day after its submission. NEPA requires that an agency take a “hard look” at the environmental consequences of a proposed major action. Kleppe v. Sierra Club, 427 U.S. 890, 410 n. 21, 96 S.Ct. 2718, 49 L.Ed.2d 576 (1976). The cursory one-day review undertaken by FHWA, which was the final agency action on a project of considerable magnitude and controversy, indicates a complete disregard for this “hard look” requirement. When considered in combination with the non-conformity announcement on the next day, Federal Defendants’ one-day review of the ROD constitutes bad faith in performing a statutorily imposed duty. The decision to reopen the entire NEPA process, which alone would not indicate bad faith conduct, provides further evidence that Federal Defendants would not have issued the ROD so rapidly had they undertaken a more deliberate consideration of the environmental analysis for the Western Section. As a result, the court finds attorney’s fees and expenses warranted under 28 U.S.C. § 2412(b). III. 28 U.S.C. § 21.12(d)(1)(A) and N.C.G.S. § 6-19.1 In addition to satisfying the requirements of 28 U.S.C. § 2412(b), Plaintiffs also meet the statutory requirements for fees and expenses under Section 2412(d)(1)(A) of the Equal Access to Justice Act and Section 6-19.1 of the North Carolina General Statutes. Section 2412(d)(1)(A) of the Equal Access to Justice Act states that “[e]xcept as otherwise specifically provided by statute, a court shall award to a prevailing party other than the United States fees and other expenses ... unless the court finds that the position of the United States was substantially justified or that special circumstances make an award unjust.” 28 U.S.C. § 2412(d)(1)(A). North Carolina General Statutes § 6-19.1 provides: In any civil action, ... brought by the State or brought by a party who is contesting State action pursuant to G.S. 150B-43 or any other appropriate provisions of law, unless the prevailing party is the State, the court may, in its discretion, allow the prevailing party to recover reasonable attorney’s fees to be taxed as court costs against the appropriate agency if: (1) The court finds that the agency acted without substantial justification in pressing its claim against the party; and (2) The court finds that there are no special circumstances that would make the award of attorney’s fees unjust. N.C. Gen.Stat. § 6-19.1. Because of the similarities in the language and requirements of the federal and state provisions, the state courts, when construing N.C.G.S. § 6-19.1, have looked to the federal courts’ interpretation of 28 U.S.C. § 2412(d)(1)(A). See Crowell Constructors, Inc. v. State ex rel. Cobey, 342 N.C. 838, 843-44, 467 S.E.2d 675, 679 (1996). Accordingly, this court will address Plaintiffs’ entitlement to attorney’s fees and expenses under 28 U.S.C. § 2412(d)(1)(A) and N.C.G.S. § 6-19.1 under the same standards. A. Issue of substantial justification Plaintiffs are entitled to fees and expenses under 28 U.S.C. § 2412(d)(1)(A) and N.C.G.S. § 6-19.1 only if the position taken by Defendants was not “substantially justified” and special circumstances do not make an award of attorney’s fees unjust. 28 U.S.C. § 2412(d)(1)(A); N.C. Gen.Stat. § 6-19.1. The “position” taken by Defendants, as defined in the Equal Access to Justice Act, includes the position taken by Defendants in the civil action and “the action or failure to act by the agency upon which the civil action is based.” 28 U.S.C. § 2412(d)(2)(D). Under the Equal Access to Justice Act, “substantially justified” means “justified in substance or in the main-that is, justified to a degree that could satisfy a reasonable person.” Pierce v. Underwood, 487 U.S. 552, 565, 108 S.Ct. 2541, 101 L.Ed.2d 490 (1988); see also Whiteco Industries, Inc. v. Harrelson, 111 N.C.App. 815, 819, 434 S.E.2d 229, 233 (1993) (applying same standard to an award of attorney’s fees under N.C.G.S. § 6-19.1). Defendants bear the burden of proving by a preponderance of the evidence that their positions were substantially justified. See Reich 98 F.3d at 150-51; see also Whiteco Industries, 111 N.C.App. at 819, 434 S.E.2d at 233. Plaintiffs claim that Federal Defendants were not substantially justified in considering the ROD for only one day prior to issuance. Since the court has already found that Plaintiffs carried the burden of showing bad faith conduct based on this allegation, a fortiori Federal Defendants were not substantially justified in issuing the ROD in the manner they did. Plaintiffs also argue that Defendants were not substantially justified in their production and approval of an inadequate final environmental impact statement for the Western Section. This allegation requires the court to examine whether the FEIS complies with NEPA and NCEPA. The purposes for NEPA are twofold: to ensure that agencies will carefully consider detailed information concerning significant environmental impacts and to guarantee that the relevant information will be made available to the public. See Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 349, 109 S.Ct. 1835, 104 L.Ed.2d 351 (1989). NEPA seeks to accomplish these goals by requiring agencies to disclose the environmental effects associated with a proposed project. NEPA forces disclosure by requiring agencies to issue an environmental impact statement, a document which must include a detailed discussion of: (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the plan 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) irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented. 42 U.S.C. § 4332(C). Although NEPA “sets forth procedural mechanisms to ensure proper consideration of environmental concerns, it does not mandate particular substantive results.” See Carmel-by-the-Sea v. United States Dep’t of Transp., 123 F.3d 1142, 1150 (9th Cir.1997). NEPA focuses on procedure. It requires that an agency take a “hard look” at the environmental consequences of a proposed action, not that the agency select the most environmentally benign alternative. See Natural Resources Def. Council, Inc. v. Morton, 458 F.2d 827, 838 (D.C.Cir.1972). NEPA contains no independent private right of action, but the Administrative Procedure Act (“APA”) expressly provides a right to judicial review of all final agency actions, including NEPA decisions. See 5 U.S.C. § 702 (“A person suffering legal wrong because of agency action, or adversely affected or aggrieved by agency action within the meaning of a relevant statute, is entitled to judicial relief thereof.”); see also N.C. Gen.Stat. § 150B-43 (providing an analogous right to judicial review under North Carolina law). The court’s scope of review under the APA is to determine whether the challenged agency action was “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” or whether the agency undertook action “without observance of procedure required by law.” 5 U.S.C. § 706(2)(A), (D). When reviewing agency action under the APA, the court cannot “substitute its judgment for that of the agency.” Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 416, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971), abrogated on other grounds, Califano v. Sanders, 430 U.S. 99, 97 S.Ct. 980, 51 L.Ed.2d 192 (1977); see also Kleppe v. Sierra Club, 427 U.S. 390, 410 n. 21, 96 S.Ct. 2718, 49 L.Ed.2d 576 (1976) (“The only role for a court is to insure that the agency has taken a ‘hard look’ at environmental consequences; it cannot interject itself within the area of discretion of the executive as to the choice of the action to be taken”). Nevertheless, deference to agency expertise does not “shield [an agency] from a thorough, probing, in-depth review.” Overton Park, 401 U.S. at 415, 91 S.Ct. 814. An agency violates the APA (and in this case NEPA) if it relies on factors Congress did not intend for it to consider, fails to examine an important aspect of the problem, offers an explanation for its decision that contradicts the evidence before the agency, or is so implausible that it cannot be attributed to a product of agency expertise. See Motor Vehicle Mfrs. Ass’n v. State Farm Mut., 463 U.S. 29, 43, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983). While the burden of proof under the APA, and consequently under NEPA, is on the plaintiff, the EAJA places the burden on the agency to demonstrate that its position was substantially justified. See Sierra Club v. Marita, 46 F.3d 606, 619 (7th Cir.1995) (stating that the party challenging agency action under the APA bears the burden of proof); see also Lively v. Bowen, 858 F.2d 177, 180 (4th Cir.1988) (stating that under the EAJA the government has the burden of proving that its position was substantially justified). Since the present action is brought under the EAJA, the burden of proof is on Defendants. Therefore, to avoid an award of fees and expenses, Defendants must show that they were substantially justified in preparing and approving the FEIS. “[W]hen determining whether the government’s position in a case is substantially justified,” the court must “determine, from the totality of the circumstances, whether the government acted reasonably in causing the litigation or in taking a stance during the litigation.” Roanoke River Basin Ass’n v. Hudson, 991 F.2d 132, 139 (4th Cir.1993). In the present case, that determination requires an examination of the FEIS in light of NEPA’s requirements. Plaintiffs allege that the FEIS failed to comply with NEPA for several reasons, including: (1) the FEIS was too narrow in scope; (2) the FEIS’s analysis of need and purpose for the project prevented a fair comparison of alternatives to the proposed beltway; (3) the FEIS inadequately. analyzed reasonable alternatives; (4) the FEIS contained an erroneous cost-benefit analysis; (5) the FEIS did not consider adequately the beltway’s effect on air quality; (6) the FEIS did not examine sufficiently the project’s effect on development in the area and the effect of that development on the environment; (7) the FEIS failed to analyze the cumulative impacts of the project; and (8) Defendants failed to supplement the FEIS based on new information. Each of these alleged shortcomings is examined below. 1. Scope of the FEIS Although the North Carolina Highway Trust Fund describes the Winston-Salem Northern Beltway as a single, continuous loop facility stretching from I-40 west of Winston-Salem northerly to I-40 in eastern Forsyth County, Defendants elected to divide the Beltway into Western and Eastern Sections and to prepare a separate environmental impact statement for each section. See N.C. Gen.Stat. § 136-180 (describing the proposed Northern Beltway). Plaintiffs contend that this partitioning of the Northern Beltway violates NEPA. Plaintiffs argue that the FEIS should have analyzed both sections of the Northern Beltway in the same document because, “[a]s a general rule under NEPA, segmentation of highway projects is improper for purposes of preparing environmental impact statements.” Piedmont Heights Civic Club, Inc. v. More-land, 637 F.2d 430, 439 (5th Cir.1981). This rule against segmentation was developed to prevent the piecemeal environmental analysis of interrelated projects, which could give an inaccurate impression of overall environmental effects. See Taxpayers Watchdog, Inc. v. Stanley, 819 F.2d 294, 298 (D.C.Cir.1987). Plaintiffs base their argument that segmentation of the Northern Beltway was improper under FHWA regulations and Fourth Circuit case law. An additional set of federal regulations, known as CEQ regulations, also addresses the proper scope' of an environmental impact statement. a. FHWA regulations Segmentation may be proper in some instances and the FHWA has developed a regulation for determining when segmentation may be allowed. According to this FHWA regulation, segmentation may be permitted when the resulting segments: (1) Connect logical termini and [are] of sufficient length to address environmental matters on a broad scope; (2) Have independent utility or independent significance, i.e., [are] usable and [are] a reasonable expenditure even if no additional transportation improvements in the area are made; and (3)[Do] not restrict consideration of alternatives for other reasonably foreseeable transportation improvements. 23 C.F.R. § 771.111(f). Each of the factors set forth in the FHWA regulation bears on whether segmentation is proper. In the context of a highway within a single metropolitan area, as opposed to a highway connecting different cities, courts have focused primarily on whether the segment has “independent utility” and placed less emphasis on the other two factors. See, e.g., Coalition on Sensible Transp., Inc. v. Dole, 826 F.2d 60, 69 (D.C.Cir.1987); Piedmont Heights, 637 F.2d at 440. i. logical termini and sufficient length Plaintiffs argue that selection of any termini for the Western Section was improper because, “the Western and Eastern Sections are one project, they are one road intended to create a single loop around the city of Winston-Salem. A loop, by definition, can have no logical termini and thus both sections should have been evaluated in a single, comprehensive environmental impact statement.” (Pis.’ Mem. in Opp’n to Fed. Defs.’ Mem. Regarding Substantial Justification [Doc. # 63] at 15). Plaintiffs cite a comment by the EPA to support their position that the Beltway project should not have been segmented. After reviewing the FEIS, the EPA stated in a letter to State Defendants that, “[planning and evaluations of urban beltway projects should be done comprehensively. Otherwise, setting end termini for a middle segment biases the planning of the adjoining segments. This is the case with this beltway project.” (ROD, Appendix B, Letter from Mueller to Vick of 4/23/96, at 2). Plaintiffs’ argument fails to consider the . definition of “logical termini.” An FHWA policy and procedure memorandum has defined “logical termini” to include major crossroads, population centers, major traffic generators, or similar highway control elements. 37 Fed.Reg. 21,810 (1972). The proposed Western Section was planned to extend from U.S. 158 southwest of Winston-Salem to U.S. 52 in the north. These major crossroads satisfy the definition of “logical termini,” and therefore the Western Section complies with 23 C.F.R. § 771.111(f) by connecting logical termini. The Western Section was also of sufficient length to address environmental concerns on a broad scope. Alternatives for the Western Section ranged in length from 16.3 to 17.6 miles, and the preferred alternative measured 17.3 miles in length. Other courts that have addressed this issue have held that even shorter highway sections satisfy the “sufficient length” requirement. For example, in Association Concerned About Tomorrow, Inc. v. Dole, 610 F.Supp. 1101 (N.D.Tex.1985), the court found that two Segments of proposed highway construction, one segment 22.9 miles long and the other only 3.4 miles long, were both of sufficient length to address environmental matters on a broad scope. See id. at 1108-09 (stating “[t]he lengths of highway covered in each EIS are theoretically sufficient for [consideration of environmental matters on a broad scope]”); Save Barton Creek Ass’n v. Federal Highway Admin., 950 F.2d 1129, 1140-42 (5th Cir.1992) (finding that if NEPA requirements had applied, a 5.5 mile long stretch of highway was sufficiently lengthy). In contrast, the court in Thompson v. Fugate, 347 F.Supp. 120 (E.D.Va.1972), found that partitioning an 8.3 mile section of a 75-mile circumferential beltway around Richmond violated NEPA. In Fugate, however, the court’s decision turned on the fact that the defendants segmented out the 8.3 mile portion of highway in an attempt to avoid the application of NEPA to an area with significant historical importance. The defendants in Fugate planned to fund the •partitioned section of highway exclusively with state monies and thereby avoid NEPA requirements for that section. In clear distinction from Fugate, Defendants in the instant case did not try to dodge NEPA requirements with respect to the Western Section. Although Defendants partitioned the Northern Beltway, they attempted to comply with NEPA by preparing environmental impact statements for both resulting sections of the Beltway. Considering the precedent case law on this issue, the proposed Western Section was of sufficient length to address environmental matters on a broad scope. ii. independent utility In determining the issue of independent utility for the Western Section, the court must examine whether the segment is “usable and [is] a reasonable expenditure even if no additional transportation improvements in the area are made.” 23 C.F.R. § 771.111(f)(2). Plaintiffs argue that the primary purpose of the Western Section is to connect with the subsequently constructed Eastern Section to provide a single continuous loop around Winston-Salem. According to Plaintiffs, the relation between these two segments indicates that the Western Section has no independent utility. Plaintiffs further contend that the similarity between the stated purposes for the Western and Eastern Sections demonstrates each section’s lack of independent utility. The FEIS states that the Western Section will “correct circumferential deficiencies in the current radial dominated road network in Western Forsyth County” as well as relieve congestion on the principal arterials and serve the future travel needs of a rapidly growing area. (FEIS at S-2). Meanwhile, the proposed Eastern Section will provide orderly and planned relief to traffic congestion in the northeast Winston-Salem area and will connect U.S. 52 with U.S. 421/140-Business. {See Fed. Defs.’ Mem. Regarding Substantial Justification [Doc. # 57] at 3). Plaintiffs argue that these purposes amount to a distinction without a difference. According to Plaintiffs, both Sections serve the same purpose: to provide a route around the city. The only difference is that one Section is on the west side of the city, the other on the east. Plaintiffs argue that this similarity in purpose undercuts Defendants’ position that each Section has independent utility. Defendants do not dispute that the proposed construction of the Western Section represents the first step in a larger project, the development of the Northern Beltway, which has been contemplated by policy-makers for decades and scheduled for funding since passage of the North Carolina Highway Trust Fund in 1989. Defendants admit the relationship between the Western and Eastern Sections in the draft environmental impact statement for the Eastern Section, which states: Completion of the Northern Beltway will provide a loop facility encircling the northern section of Winston Salem .... A feasibility study of the Northern Beltway (Eastern Section) Extension from U.S. 421/1-40 Business to U.S. 311 Freeway is currently under study by NCDOT. A missing link or gap in this loop would occur if the, Northern Beltway projects were not completed. As a result, the Winston-Salem area would not receive the maximum economic and road-user benefits associated with a complete circumferential transportation system. (Pis.’ Mem. in Opp’n to Federal Defs.’ Mem. Regarding Substantial Justification [Doc. # 63], Ex. 2 at 1-5) (emphasis added). Nevertheless, the plan eventually to connect the Western and Eastern Sections of the Northern Beltway does not render each section without independent utility. The Western Section could fulfill its stated purpose-to improve north-south travel in the radial-dominated suburbs of western Forsyth County, relieve congestion on principal arterial roads, improve safety by reducing traffic in residential areas, and serve the travel needs of a rapidly growing area-regardless of whether the Eastern Section were ever constructed. In addition, even though the Western and Eastern Sections might serve similar purposes, relieving congestion on their respective sides of the city, this does not prevent each from having independent utility. As defined in FHWA regulations, independent utility does not mean unique utility. Instead, it means that the segmented portion “[is] usable and [is] a reasonable expenditure even if no additional transportation improvements in the area are made.” 23 C.F.R. § 771.111(f)(2); see also Coalition on Sensible Transp., 826 F.2d at 69 (“The proper question is whether one project will serve a significant purpose even if a second related project is not built.”). The fact that the Western and Eastern Sections might serve the same functions in different locations has no bearing on whether each has independent utility. Moreover, even though the Western Section might not achieve its maximum utility without construction of the Eastern Section, that does not necessarily lead to the conclusion that the Western Section does not have substantial independent utility. The plain language of 23 C.F.R. § 771.111(f)(2) requires only that the Western Section have independent utility, not that it attain its maximum potential utility. The court finds the Western Section to have independent utility as defined in 23 C.F.R. § 771.111(f)(2). iii. restrict consideration of alternatives Plaintiffs also argue that analyzing the environmental impact of the Western Section separately from the Eastern Section restricts the consideration of alternatives for other “reasonably foreseeable transportation improvements.” 23 C.F.R. § 771.111(f)(3). The location of the Western Section inevitably anchors any future connection point between the Western and Eastern Sections. To this extent, alternatives for the Eastern Section are restricted. This alone, however, does not suffice to show that Defendants acted arbitrarily or capriciously by segmenting the Northern Beltway. Every segmentation, even those undertaken in compliance with FHWA regulations restricts the location of future connecting transportation improvements. See Save Barton Creek, 950 F.2d at 1142 (finding that the siting of one portion of a loop roadway did not dictate the construction of any other segment, the size of any other segment, or the alignment of the rest of the loop); Clairton Sportsmen’s Club v. Pennsylvania Turnpike Comm’n, 882 F.Supp. 455, 473 (W.D.Pa.1995) (finding that some restriction on the siting of subsequent roadway segments due to the placement of a previously constructed roadway segment is permissible under NEPA). Once the location for one segment is determined, a subsequently constructed connecting segment must meet the first segment at a fixed point of intersection. As a result, all projects with connecting segments, even those partitioned in compliance with FHWA regulations, minimally restrict the consideration of alternatives for future transportation improvements. The proper question, then, is not whether segmentation restricts the location of the endpoints to reasonably foreseeable transportation improvements, but whether segmentation restricts the location of an appreciable length of future alternatives. In this case, setting the location of the Western Section did not extensively restrict alternative locations for the Eastern Section. The FEIS indicates that Defendants performed environmental analyses far enough beyond the northern terminus at U.S. 52 to ensure that alternatives for the Eastern Section were not restricted and that the Eastern Section would not have significant environmental impacts as a result of the location of the Western Section. (See FEIS at 2-9) (stating that five northern endpoints for the Western Section as well as direct and staggered connections between the sections were considered). Furthermore, the FEIS states that the selected location of the northern terminus is the best alternative based on the function of the transportation network, disruption to business and residential areas, impacts to historic sites, and costs. (FEIS at 7-21). Such a determination is a matter of agency expertise beyond the court’s scope of review. By ensuring that the location of the Western Section would still permit a significant number of potential locations for the Eastern Section, the Defendants avoided restricting the consideration of alternatives for other reasonably foreseeable transportation improvements. Consequently, the court finds that Defendants did not violate FHWA regulations in segmenting the Northern Beltway. b. CEQ regulations and case law FHWA regulations allow for segmentation of proposed actions if certain criteria are met. In contrast, regulations issued by the Council on Environmental Quality (“CEQ”) direct agencies as to when segmentation should not occur. CEQ regulations are binding on all federal agencies and are entitled to substantial deference. See Andrus v. Sierra Club, 442 U.S. 347, 358, 99 S.Ct. 2335, 60 L.Ed.2d 943 (1979); Sugarloaf Citizens Ass’n v. Fed. Energy Regulatory Comm’n, 959 F.2d 508, 512 n. 3 (4th Cir.1992). In pertinent part, CEQ regulations prescribe the scope of the environmental impact statement as follows: Scope consists of the range of actions, alternatives, and impacts to be considered in an environmental impact statement. ... To determine the scope of environmental impact statements, agencies shall consider 3 types of actions, 3 types of alternatives, and 3 types of impacts. They include: (a) Actions (other than unconnected single actions) which may be: (2) Cumulative actions, which when viewed with other proposed actions have cumulatively significant impacts and should therefore be discussed in the same impact statement. 40 C.F.R. § 1508.25 (emphasis in original). Although federal agencies are given “the primary task of defining the scope of NEPA review and their determination is given considerable discretion, ... cumulative actions must be considered together to prevent an agency from dividing a project into multiple actions, each of which individually has an insignificant environmental impact, but which collectively has a substantial impact.” Wetlands Action Network v. United States Army Corps of Eng’rs, 222 F.3d 1105, 1118 (9th Cir.2000) (internal quotations omitted). The Western and Eastern Sections constitute cumulative actions, and therefore should have been considered in the same environmental impact statement. In Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir.1998), the Ninth Circuit held that a single environmental impact statement should have been prepared for five related timber sales. The court found the sales were cumulative actions because they were part of a single project, were announced simultaneously, and were reasonably foreseeable. Id. at 1214-15. Similarly, in the present case, the Western and Eastern Sections constitute portions of a single project, the Northern Beltway; funding for the Western and Eastern Sections was announced simultaneously in the North Carolina Trust Fund; and construction of the Western and Eastern Sections was reasonably foreseeable. In addition, the Western and Eastern Sections together would have destroyed over 900 acres of woodland, 15 acres of wetland, and nearly 1000 acres of prime and important farmland. The proposed Northern Beltway would have impacted over 85 acres of flood plains, required the relocation of 2500 feet of stream channels, and forced the relocation of over 500 residences. When viewed in combination, the Western and Eastern Sections have cumulatively significant environmental impacts. Therefore, under CEQ regulations the sections should have been considered in the same impact statement. See Swain v. Brinegar, 542 F.2d 364, 368 (7th Cir.1976) (en banc) (“[Although the individual environmental impact [of a segmented project] might be slight, the cumulative consequences could be devastating.”); Resources Ltd., Inc. v. Robertson, 35 F.3d 1300, 1306 (9th Cir. 1993) (“[WJhere several foreseeable similar projects in a geographic region have a cumulative impact, they should be evaluated in a single EIS.”) (internal quotations and citation omitted). The decision not to examine the environmental effects of the Western and Eastern Sections in the same document disregarded the CEQ regulation regarding scope of an environmental impact statement. In addition to the federal regulations already discussed, the Fourth Circuit has affirmed consideration of “the manner in which the roads were planned [and] their geographic locations” as factors that should be considered in determining the proper scope of an environmental impact statement. James River & Kanawha Canal Parks, Inc. v. Richmond Metro. Auth., 359 F.Supp. 611, 635 (E.D.Va.1973), aff'd, 481 F.2d 1280 (4th Cir.1973). As described in statutory language and in planning documents, the Northern Beltway, consisting of the Western and Eastern Sections, is located entirely within Forsyth County. The two Sections of the Beltway were planned to intersect north of the city. This intersection would have given the Sections geographic proximity. In addition, the Beltway has always been considered and treated as a single project by legislators and planners. As stated in the FEIS, “[a] loop facility, identified as the Northern Beltway, has been a part of local and state transportation planning since the 1960’s.” (FEIS at 1-2). Moreover, the North Carolina Highway Trust Fund Law, which grants funding for the loop, treats the Beltway as a single project. See N.C. Gen Stat. § 136-180 (1999). Finally, the region’s major planning documents, Winston-SalemlForsyth County Thoroughfare Plan (1989) and Vision 2005, also contemplate the Northern Beltway as a single project. Because of the geographic proximity and common planning of the Western and Eastern Sections, they should have been considered in the same environmental impact statement. Failure to do so disregarded the factors approved by the Fourth Circuit in James River and failed to consider an important aspect in analyzing the environmental consequences of the proposed Beltway project. Consequently, Defendants’ decision to analyze the Western and Eastern Sections of the Northern Beltway in separate documents violated NEPA as interpreted in CEQ regulation and Fourth Circuit case law. 2. Purpose and need The environmental impact statement shall “briefly specify the underlying purpose and need to which the agency is responding in proposing the alternatives including the proposed action.” 40 C.F.R. § 1502.13. Plaintiffs allege that Defendants defined the purpose of the Western Section project'too narrowly, thereby preventing a fair consideration of alternatives to the proposed Beltway. Defendants respond that the purpose of the project was properly defined in that it permitted consideration of non-Beltway alternatives. Plaintiffs further allege that the need for the project was never definitively established in the FEIS. Defendants also refute this allegation. a. Purpose The defined purpose of a proposed action may greatly affect the feasibility of alternatives. “The stated goal of a project necessarily dictates the range of ‘reasonable’ alternatives and an agency cannot define its objectives in unreasonably narrow terms.” Carmel-by-the-Sea, 123 F.3d at 1155. If the purpose is defined too narrowly, “only one alternative from among the environmentally benign ones in the agency’s power would accomplish the goals of the agency’s action, and the EIS would become a foreordained formality.” Citizens Against Burlington, Inc. v. Busey, 938 F.2d 190, 196 (D.C.Cir.1991). Plaintiffs argue that Defendants defined the purpose of the Western Section project in such a way that only a circumferential road would suffice. As evidence of this, Plaintiffs point to statements in the FEIS explaining the dismissal of various proposed alternatives. For example, in summarizing the decision to dismiss certain alternatives to the construction of the Western Beltway Section, Defendants stated that “alternatives have been evaluated and were found to be incapable of providing effective solutions to the need for circumferential roadway improvements.” (FEIS at 2-50) (emphasis added). Plaintiffs contend that this purpose, to improve circumferential mobility, effectively eliminated all non-beltway alternatives from consideration. As a result, Plaintiffs argue that the purpose of the project was too narrow in scope. Plaintiffs are correct that circumferential connection of existing roads was one of the major goals for construction of the Western Section, but this does not mean that Defendants defined the purpose for the project too narrowly. In Sierra Club v. United States Dep’t of Transp., 962 F.Supp. 1037 (N.D.Ill.1997), the court found that a FEIS proposing construction of a tollroad did not define the purpose of the project too narrowly even though providing a north-south corridor constituted one of the project’s major objectives. Id. at 1042-43. In addition to this relatively narrow goal, several more general objectives factored into the analysis and ultimate dismissal of alternatives to the toll-road. The court stated that because these broader objectives played a significant part in defining the purpose for the project, the purpose was not defined too narrowly. Western Forsyth County’s current transportation system was built for the purpose of bringing agricultural goods and supplies from outlying rural areas into Winston-Salem. As a result, most of the roads are radial in nature, running from former farming regions to 'the center of the city like spokes to a hub. These radial roadways lack a continuous connecting road. To move north or south between radial roadways, residents of western For-syth County must take circuitous routes through residential areas. As western Forsyth County has become more suburban in character, the need to move north and south to reach employment, shopping, and recreation destinations has become more acute. In proposing the Western Section, planners sought to provide a continuous north-south connecting road that would link the existing radial roadways. The intention of connecting roadways was entirely reasonable, and constituted only one of several more general goals for the Western Section. In addition to linking radial roads, the FEIS discusses other transportation problems in western Forsyth County that the proposed project sought to correct. For example, planners hoped to (1) improve local travel; (2) improve safety; (3) alleviate overflow traffic on currently existing roads; (4) accommodate shifting locations of employment; and (5) ameliorate pollution problems by reducing congestion. These goals all constitute legitimate objectives. Linking radial roadways with a north-south connector is also a reasonable objective. While these objectives limited the range of alternatives that would satisfy the purpose of the project, some limit on alternatives is necessary. See Citizens Against Burlington, 938 F.2d at 196 (“[A]n agency [may not] frame its goals in terms so unreasonably broad that an infinite number of alternatives would accomplish those goals and the project would collapse under the weight of the possibilities.”). In light of these legitimate objectives, and after consideration of various alternatives, the FEIS concluded that a circumferential roadway would best serve the overall purpose of the project. This conclusion does not indicate that the purpose was defined too narrowly. b. Need Plaintiffs also claim that Defendants failed to show a need for the project in the first place. Plaintiffs argue that, although the FEIS states that the Beltway project “has been a part of local and state transportation planning since the 1960s,” Defendants never set forth reliable empirical data demonstrating the need for the project. (FEIS at 1-2). In the FEIS, Defendants stated that the “[ajverage daily traffic volumes for a new freeway facility located in the preferred corridor range from a low of 30,300 vehicles per day (vpd) ... to a high of 48,800 vpd.” (FEIS at 1-34). A year prior to publication of the FEIS, however, Defendants acknowledged that these estimates were overstated, and reduced the traffic volume projections to between 12,000 and 32,000 vehicles per day. (Pis.’ Mem. in Supp. of Their Mot. for a T.R.O. and Prelim. Inj. Relief [Doc. # 3], Ex. 14 at 2). When Plaintiffs questioned the use of inflated traffic figures in the FEIS, Defendants responded that the decision to use the higher estimates was made “because these projections would present a worst case scenario for the impacts to the human and natural environment and would also show the worst case for noise and air quality impacts.” (Pis.’ Mem. in Supp. of Their Mot. for a T.R.O. and Prelim. Inj. Relief [Doc. # 3], Ex. 8 at 11). Defendants also stated in the record of decision that even with the reduced traffic estimates, a need for the proposed facility existed. Id. The court defers to Defendants’ conclusion that a need for the project existed' even with the reduced traffic projections. The purposeful inclusion of inaccurate data in the FEIS, however, is a different matter. “If the district judge finds that the agency did not make a reasonably adequate compilation of relevant information and that the EIS sets forth statements that are materially false or inaccurate, he may