Full opinion text
OPINION PAUL L. FRIEDMAN, District Judge. I. INTRODUCTION This case, brought under the National Environmental Policy Act (“NEPA”) and other federal environmental statutes, arises from decisions of the Bureau of Land Management (“BLM”) and other federal agencies facilitating the construction of a refined petroleum products pipeline from Bloomfield, New Mexico to Salt Lake City, Utah. Comprising 220 miles of natural gas pipeline proposed to be converted to petroleum products use and 260 miles of newly constructed pipeline, the pipeline traverses primarily private lands but also crosses the Manti-La Sal and Uinta National Forests. Defendant-Inter-venor, the Williams Pipe Line Company (“Williams”), a common carrier of petroleum products, seeks by construction of this .pipeline to provide access to the potentially lucrative petroleum products market in Salt Lake City. Primarily at issue in this case is the relationship between the proposed Williams pipeline and another proposed pipeline, set to run from Odessa, Texas to Bloomfield, New Mexico. The proponent of that project, Equilon Pipeline LLC (“Equilon”), formerly was partnered with Williams in a joint venture to construct a single pipeline encompassing both of the proposed segments and running all the way from West Texas to Salt Lake City. The full pipeline would connect Salt Lake City to the national petroleum products grid, including high-capacity refineries in West Texas and shipping terminals on the Texas Gulf Coast. When BLM, the agency primarily responsible for reviewing applications for rights-of-way for utility corridors across federal lands, made it clear to Equilon and Williams that, for purposes of NEPA environmental review, BLM would consider the entire proposed Odessa to Salt Lake City pipeline as a single project, rather than two separate endeavors, Williams and Equilon terminated the joint venture and applied separately for rights-of-way to construct their respective pipelines across federal lands. BLM ultimately granted Williams’ application for a right-of-way after preparing a final environmental impact statement (“FEIS”) that did not address the environmental impacts of the proposed Equilon pipeline. Plaintiffs in this case are Sinclair Oil, a petroleum products company with a current presence in the Salt Lake City market; several environmental groups concerned with pipeline safety; and individuals owning land on or near the proposed Williams pipeline route. The plaintiffs raise a host of claims, foremost among which is the assertion that BLM improperly limited the scope of the Williams FEIS to exclude the Equilon pipeline, allowing the impact of the Equi-lon project to be considered in a separate environmental review process and preventing the full environmental impacts of the combined projects from being considered adequately in the ROW decision-making process. Plaintiffs also assert other defects in the FEIS and claim that BLM was required by law to prepare a supplemental environmental impact statement (“SEIS”) based on information that came to light after the issuance of the FEIS. Plaintiffs raise additional claims under the Endangered Species Act, the Mineral Leasing Act, and the National Forest Management Act. Before the Court are two sets of cross-motions for partial summary judgment and defendant-intervenor Williams Pipe Line Company’s motion to dismiss Count 13 of the amended complaint. As provided in this Court’s Order of March 31, 2005, the Court granted summary judgment for plaintiffs on Count 1 of their amended complaint, which alleges that BLM improperly segmented its environmental analysis of the Williams project, and remanded the matter to BLM for the preparation of a Supplemental Environmental Impact Statement addressing only the issue of whether the Williams and Equilon pipeline projects are “connected actions” under 40 C.F.R. § 1508.25(a)(1). The Court granted summary judgment for defendants on all other counts. This Opinion explains the reasoning underlying the Court’s Order of March 31, 2005. II. BACKGROUND A. History of the Williams, Equilon, and Aspen Projects This case arises from defendant-interve-nor Williams Pipe Line Company’s effort to construct a petroleum products pipeline providing access to the Salt Lake City, Utah petroleum products market. Salt Lake City historically has been isolated from the national petroleum products grid. At the time the Williams project was initiated, nearly all the refined petroleum products in the state of Utah were supplied by five small in-state refineries and one Wyoming refinery owned by plaintiff Sinclair Oil. As a result, prices for gasoline and other petroleum products in Utah are considerably higher than they are in most parts of the country connected to the national grid. Williams asserts that if the Utah market were connected to the massive refineries on the Texas Gulf Coast, competition would increase and prices would drop considerably. Williams proposes to build a petroleum products pipeline connecting the Salt Lake City area with Bloomfield, New Mexico, a town near the “Four Corners” area (where Utah, New Mexico, Arizona, and Colorado meet), which also is not currently connected to the national petroleum products grid. Two hundred twenty miles of the line would be converted from an existing natural gas pipeline extending from Bloomfield to Crescent Junction, Utah. The 260-mile section from Crescent Junction to Salt Lake City, however, would consist of newly constructed pipe, 96.95 miles of which would traverse federal lands, including the Manti-La Sal and Uinta National Forests. See U.S. Department of the Interior, Record of Decision for the Williams Petroleum Products Pipeline Project (Oct. 12, 2001) (“Oct.2001 ROD”) at 1, A.R. vol. .6 at 123. The Mineral Leasing Act, 30 U.S.C. §§ 181 et seq., requires Williams to obtain a right-of-way (“ROW”) from the Bureau of Land Management, a subdivision of the Department of the Interior (“DOI”), before it can construct, operate, or maintain a pipeline on federal lands. Williams filed .an initial ROW application with the Utah office of BLM in 1998. See Oct. 2001 ROD at 1, A.R. vol. 6 at 128. Although that application pertained only to the segment of the pipeline running from Thompson Springs, Utah to the Salt Lake City, area, the application stated that this pipeline segment was part of a larger project to build a pipeline extending all the way from southeast Texas to “the Wasatch Front area of Utah,” in the vicinity of Salt Lake City. See Supplement to Application for Transportation and Utility Systems and Facilities on Federal Lands (Nov. 6, 1998) (“Nov.1998 Williams Application”) at 1, A.R. vol. 1 at 324. A separate application for the New Mexico segment of the project was tó be filed with BLM in Farmington, New Mexico. See id. In February 1999, Williams and another company, Equilon Pipeline LLC, formed a joint venture, Aspen Products Pipeline LLC (“Aspen”), to construct a petroleum products pipeline from Odessa, Texas to Salt Lake City. See DefendanNInterve-nors’ Statement of Points and Authorities in Opposition to Plaintiffs’ Motion for Partial Summary Judgment and in Support of Motion for Summary Judgment and Motion to Strike (“Def-Intervs’. Opp. 1st Mot. Summ. J.”) at 3-4. A March 15,1999 amendment to the Williams ROW application redesignated Aspen as the proponent of the project and extended the northern terminus of the line slightly. See id. at 4; Letter from John R. Thomas to Mark Mackiewicz (March 15, 1999), Re: Williams Pipe Line Company Revised Right-of-Way Application, A.R. vol. 1 at 235. Also under the aegis of Aspen, Equi-lon filed a ROW application with the New Mexico office of BLM for the southern segment of the pipeline, running from Odessa, Texas, to Bloomfield. The National Environmental Policy Act, 42 U.S.C. §§ 4321 et seq., provides that a federal agency must prepare an environmental impact statement for “proposals for ... major federal actions significantly affecting the quality of the human environment.” 42 U.S.C. § 4332(2)(C); see also 40 C.F.R. § 1502.3. NEPA and its implementing regulations require the agency preparing an EIS to consider carefully the scope of its analysis, defined by Council on Environmental Quality (“CEQ”) regulations as “the range of actions, alternatives, and impacts to be considered in an environmental impact statement.” 40 C.F.R. § 1508.25. Actions that are “connected” or “cumulative” in impact should be discussed in the same environmental impact statement; actions that are “similar” may be analyzed in the same statement. 40 C.F.R. § 1508.25(a). After meeting with Williams and Equi-lon, and over the companies’ strenuous objections, BLM decided that rather than prepare separate EIS’s for the northern and southern segments of the pipeline, BLM would for NEPA purposes examine the entire Aspen pipeline from Odessa to Salt Lake City as a single project. See Letter from Sally Wisely, Director, Utah Office of BLM, to Tim Powell, Williams Energy Services (Feb. 1, 2000) (“Feb.2000 Wisely Letter”), A.R. vol. 8 at 449. The Environmental Protection Agency, the Council on Environmental Quality, Sinclair Oil (a plaintiff here), and other interested parties also had submitted comments urging BLM to examine the entire Aspen projeet in a single EIS. See Statement of Uncontested Facts in Support of Motion of Plaintiffs and Plaintiff-Intervenors for Partial Summary Judgment (“Pls’.Facts”) ¶¶ 8-13. Because the two segments were to be considered as part of a single environmental review process, construction of either segment could not begin until environmental review of the entire pipeline was completed. As a direct consequence of BLM’s decision to prepare a single EIS, in March 2000 Williams and Equilon decided to terminate the Aspen joint venture and construct separately the northern and southern segments of the proposed pipeline. Williams filed another amended application to “clarify” that its pipeline would end in Bloomfield and that Williams would “no longer include Equilon’s proposed pipeline as an alternative source of supply” for its line. See Letter from Tim Powell to Sally (March 8, 2000) (“Mar.2000 Powell Letter”), A.R. vol. 8 at 451. Williams further requested that its ROW application be reviewed independently of any ROW application filed by Equilon. Id. The amended ROW application described the proposed project as “a pipeline to transport refined petroleum products from Bloomfield, New Mexico to the Wasatch Front area of Utah.” See Application for Transportation and Utility Systems and Facilities on Federal Lands, Amended, March 2000 (March 8, 2000), A.R. vol. 8 at 458. Equilon also filed an amended ROW for its segment of the pipeline, still proposed to extend from Odessa to Bloomfield. See Pis’. Facts ¶ 18. On April 19, 2000, DOI published in the Federal Register a notice of intent to proceed with an EIS addressing the Williams pipeline, as well as natural gas pipelines proposed by Questar Pipeline Company (“Questar”) and Kern River Gas Transmission Company (“Kern”), which would traverse largely the same route across federal lands as the Williams line. See 65 Fed. Reg. 21006 (April 19, 2000). After notice and public comment, on February 9, 2001, BLM completed the draft environmental impact statement (“DEIS”) for .the Williams project. See Williams, Questar, & Kern River Pipeline Projects: Draft Environmental Impact Statement (March 2001) (“DEIS”), A.R. vol. 2 at 1. The DEIS did not include analysis of the environmental effects of the Equilon proposal. The omission of Equilon from the DEIS elicited negative comments from numerous parties, including some of the plaintiffs in this action. The EPA, required by NEPA and the Clean Air Act to comment on the action, see 42 U.S.C. § 7609; 42 U.S.C. § 4332(2)(C), objected to the DEIS on this and other grounds. In an April 16, 2001, letter to BLM submitted during the notice and comment period, EPA raised the issue of “segmentation” in the DEIS: The DEIS needs to analyze additional connected actions that would include impacts related to the Equilon pipeline .... EPA was informed by BLM and public individuals that these two “separate projects” were once proposed as one project.... BLM and Williams have not provided any information in the DEIS such as information on supply contracts that would support the argument that the two pipelines are not connected. See Letter from Cynthia Cody, Chief, NEPA Unit, Ecosystems Protection Program, EPA to LaVerne Steah, Project Manager, Bureau of Land Management (April 16, 2001) (“Apr.2001 Cody Letter”) at 5, A.R. vol. 8 at 66. On June 1, 2001, BLM issued a final environmental impact statement for the Williams project. See Plaintiffs’ Amended Complaint (“Am.Compl.”) ¶8. The FEIS acknowledgéd the receipt of many public comments arguing for the consideration of the Williams and Equilon pipelines in a single EIS on the grounds that they were either “connected” or “cumulative” actions. See Final Environmental Impact Statement for the Questar, Williams, & Kern River Pipeline Project (June 1, 2001) (“FEIS”) § 1.8.2.4 at 1-30. BLM defended its decision to analyze the projects separately, however, on four grounds. First, “the Williams project would not automatically trigger other actions that require environmental impact statements,” as the Equilon project and its environmental analysis already were underway. Id. Second, “[t]he Williams project can and would proceed regardless of whether other actions are taken previously or simultaneously.... Williams has stated that it can acquire a supply of products for its pipeline even if the Equilon project is not constructed.” Id. Third, “[t]he Williams project is not an interdependent part of a larger action and depends on the larger action for its justification.” Finally, although BLM “aeknowledge[d] that the Equilon project is a related or foreseeable project, ... [t]he area of geographic overlap between the two projects is very small, and the potential additive effects on resources are very limited.” Id. On June 20, 2001, EPA sent a letter to BLM requesting documentation supporting the argument that the Equilon and Williams pipelines were not connected projects, and pointing out that “the only difference” between the single Aspen application and the separate Williams/Equi-lon applications “is that the two companies have dissolved the previous [partnership] agreement. CEQ does not require a formal agreement in order for two projects to be defined as connected actions.” See Letter from Cynthia Cody, Chief, NEPA Unit, Ecosystems Protection Program, EPA to LaVerne Steah, Project Manager, Bureau of Land Management at 2 (June 20, 2001) (“June 2001 Cody Letter”), A.R. vol. 8 at 69-70. BLM received no further written communication from EPA on the DEIS or FEIS. Relying on the environmental analysis in the FEIS, on June 5, 2001, the Fish and Wildlife Service (“FWS”) issued a Biological Opinion on the effect of the Williams project on numerous plant and animal species in the project area, in accordance with Section 7 of the Endangered Species Act, 16 U.S.C. §§ 1531 et seq. The Biological Opinion concluded that the Williams project would not have adverse effects on most of the species considered, and that the pipeline “may affect, but is not likely to adversely affect the endangered Colorado pikeminnow, razorback sucker, humpback chub, and bonytail in Colorado.” See Final Formal Section 7 Consultation for the Utah Portion of the Williams Pipe Line Company Proposed Pipeline Extending From Bloomfield, New Mexico to Salt Lake City, Utah (June 5, 2001) (“Bio.Op.”) at 1-2, A.R. vol. 6 at 35. FWS premised this conclusion partially on Williams’ commitment to numerous measures designed to minimize the impact of pipeline construction and operation on listed species. Id. at 2. The required environmental reviews having been substantially completed, Williams needed the approval of one more agency before it could obtain a ROW from BLM. The National Forest Management Act, 16 U.S.C. §§ 1600 et seq., requires preparation of a Land and Resource Management Plan (“Forest Plan”) governing the management of resources in each national forest. The existing plan for the Manti-La Sal National Forest, enacted in 1986, provided for a 200 to 500 foot wide utility corridor through the forest, in which underground pipeline facilities might be constructed. See Defendants’ Memorandum of Points and Authorities in Support of Cross-Motion for Summary Judgment and in Opposition to Plaintiffs’ Motion for Summary Judgment (March 7, 2003) (“Defs’.2d MotSumm. J.”) at 3-4. The FEIS for the Williams, Questar, and Kern projects, however, had identified substantial landslide risks in certain areas crossed by this utility corridor and recommended re-routing the proposed pipelines around these areas. See FEIS §§ 2.3.3 to 2.4 at 2-62 to 2-66. Use of this route, however, would require amendment of the Manti-La Sal Forest Plan to reroute portions of the utility corridor. On July 5, 2001, the United States Forest Service (“USFS”), a division of the United States Department of Agriculture (“USDA”), issued a Record of Decision (“ROD”) with respect to the Questar and Kern natural gas pipelines, approving the relocation of two segments of the utility corridor to allow short segments of the natural gas pipelines to be re-routed to avoid landslide-prone areas. See Record of Decision and Finding of Non-Significant Amendment for the Manti-La Sal and Uinta National Forest Land and Resource Management Plan Amendments (July 5, 2001) (“July 2001 ROD”), A.R. vol. 3 at 410. Although it considered the “cumulative effects” of the Williams pipeline proposal, the July 2001 ROD “[did] not make a decision regarding the location of a utility corridor for the refined petroleum products pipeline (Williams) proposal.” See July 2001 ROD at 2. On August 3, 2001, USFS issued another ROD amending the Manti-La Sal Forest Plan to allow the Williams petroleum products pipeline to follow the same amended corridor as the two natural gas pipelines. See Record of Decision and Finding Non-Significant Amendment for the Manti-La Sal National Forest Land and Resource Management Plan Amendment (August 3, 2001) (“Aug.2001 ROD”), A.R. vol. 5 at 407. As part of this ROD, USFS made a “Finding of Non-Significant Amendment” (“FONSA”) pursuant to former 36 C.F.R. § 219.10(f) (1997) (amended Jan. 5, 2005), allowing amendment of the Forest Plan by means of an expedited administrative process, rather than the extended procedure required for development and approval of a new forest plan. See Aug. 2001 ROD at 6. Plaintiffs administratively appealed the Forest Service ROD, but their appeal was denied on June 26, 2002. See Letter from Elizabeth G. Close, Acting Deputy Regional Forester, to Melvin Goldstein (June 26, 2002), A.R. vol. 52 at 550-53; Federal Defendants’ Memorandum of Points and Authorities in Support of Cross-Motion for Summary Judgment and in Opposition to Plaintiffs’ Motion for Summary Judgment (May 23, 2003) (“Fed.Defs’.2d Mot.Summ. J.”) at 9. Finally, on October 12, 2001, DOI issued a Record of Decision granting Williams’ request for a right-of-way. The ROD considered many of the environmental impacts analyzed in the FEIS, and “adopt[ed] many stringent measures to minimize risks [resulting] in a project that reduces risks to an acceptable level that is within the petroleum products industry’s norms.” See Oct. 2001 ROD at 9. B. Proceedings in this Court On November 9, 2001, plaintiffs filed a complaint for declaratory and injunctive relief against BLM, DOI, and officials thereof. The complaint asserted eleven claims under NEPA, the Administrative Procedure Act, the Mineral Leasing Act, the Endangered Species Act, and the Forest Management Act, and asked the Court to enjoin any further action with respect to the Williams pipeline pending preparation of a revised EIS and ROD. On November 28, 2001, the Court granted Williams’ motion to intervene as a defendant. With the consent of the existing parties to the action, Carol Parker and Citizens for Safe Pipelines, Inc. (“CSP”) were allowed to intervene as plaintiffs on March 18, 2002. The federal defendants filed the administrative record supporting the challenged decisions on February 15, 2002, but the record has since been supplemented numerous times by additional submissions from both sides. The Court also granted, in part, plaintiffs’ request to conduct limited discovery to complete the administrative record, to allow plaintiffs the opportunity to substantiate claims of bad faith by BLM in its environmental review of the Williams project. See Memorandum Opinion and Order (July 31, 2002). On March 25, 2002, plaintiffs and plaintiff-intervenors filed a motion for partial summary judgment on Counts 1 through 8 of the complaint. Defendants and defendant-intervenors filed cross-motions seeking summary judgment on all counts on April 29, 2002. Williams’ cross-motion also asked the Court to strike certain affidavits submitted by plaintiffs because they were outside the administrative record, and not subject to any exception to the general rule that in NEPA cases the Court’s review should be limited to the administrative record. See Def-Intervs’. Opp. 1st Mot. Summ. J. at 8-10. In July 2002, plaintiffs and plaintiff-in-tervenors sought and were granted leave to amend their complaints to add additional claims and to join USFS as an additional defendant. Counts 14, 15, and 16 challenge the legality of USFS’s August 2001 ROD under the National Forest Management Act, 16 U.S.C. §§ 1600 et seq., and the Forest Service’s own regulations, including the “Roadless Area Rule” restricting the construction of roads in certain designated areas of National Forests. The amended complaint also accuses BLM of acting arbitrarily and capriciously in refusing to prepare a supplemental EIS for the Williams project, which plaintiffs claim was necessitated by factual developments since preparation of the FEIS. On November 1, 2002, Williams filed a motion to dismiss this count (Count 13) for failure to state a claim, under Rule 12(b)(6) of the Federal Rules of Civil Procedure. On January 23, 2003, plaintiffs and plaintiff-intervenors filed another motion for partial summary judgment, this time on Counts 12 through 16 of the amended complaint. Defendants and defendant-in-tervenors again filed cross-motions for summary judgment on all claims. Pending-before the Court, then, are the parties’ and intervenors’ six motions for summary judgment and Williams’ motion to dismiss Count 13 of the amended complaint. III. DISCUSSION A. Standard of Review Under the Administrative Procedure Act (“APA”), a reviewing court may only set aside agency actions, findings, or conclusions when they are arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law. 5 U.S.C. § 706(2)(A). An agency action is arbitrary and capricious if an agency has “entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency, or is so implausible that it could not be ascribed to a difference in view or the product of agency expertise.” Motor Vehicle Mfrs’. Ass’n v. State Farm Mut. Auto, Ins. Co., 463 U.S. 29, 42, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983). Especially in complex, technical areas, there is a strong presumption in favor of upholding agency decisions. See Marsh v. Oregon Natural Resources Council, 490 U.S. 360, 375-78, 109 S.Ct. 1851, 104 L.Ed.2d 377 (1989). Nonetheless, a reviewing court must undertake a “thorough, probing, in-depth review” of the agency’s decision and then decide whether it was “based on a consideration of the relevant factors and whether there has been a clear error of judgment.” Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402, 415-16, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971). Review of agency action generally “is to be based on the full administrative record that was before the [agency] at the time [it] made [its] decision.” Id. at 420, 91 S.Ct. 814. If the agency has “considered the relevant factors and articulated a rational connection between the facts found and the choice made,” its decision must be upheld. Baltimore Gas & Elec. Co. v. Natural Resources Defense Council, 462 U.S. 87, 105, 103 S.Ct. 2246, 76 L.Ed.2d 437 (1983). For challenges to an agency's construction of the statutes that it administers, the Court's review must be particularly deferential. The Court must defer to the agency's interpretation of a statute that it implements "so long as it is reasonable, consistent with the statutory purpose, and not in conflict with the statute's plain language." OSG Bulk Ships v. United States, 132 F.3d 803, 814 (D.C.Cir.1998) (quoting Coal Employment Project v. Dole, 889 F.2d 1127, 1131 (D.C.Cir.1989)); see Chevron U.S.A. v. Natural Resources Defense Council, 467 U.S. 837, 845, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984); Davis v. Latschar, 83 F.Supp.2d 1, 5 (D.D.C.1998), aff'd, 202 F.3d 359 (D.C.Cir.2000). An agency's interpretation of its own regulations also is entitled to substantial deference by the courts. Thomas Jefferson Univ. v. Shalala, 512 U.S. 504, 512, 114 S.Ct. 2381, 129 L.Ed.2d 405 (1994); Wyoming Outdoor Council v. United States Forest Serv., 165 F.3d 43, 52 (D.C.Cir.1999). Unless "plainly erroneous or inconsistent with the regulation," the agency's construction of its own regulation is controlling. United States v. Larionoff, 431 U.S. 864, 872, 97 S.Ct. 2150, 53 L.Ed.2d 48 (1977); see also Stinson v. United States, 508 U.S. 36, 45, 113 S.Ct. 1913, 123 L.Ed.2d 598 (1993); Wyoming Outdoor Council v. United States Forest Serv., 165 F.3d at 52; Everett v. United States, 158 F.3d 1364, 1367 (D.C.Cir.1998); Amerada Hess Pipeline Corp. v. Federal Energy Regulatory Comm'n, 117 F.3d 596, 600 (D.C.Cir.1997); Davis v. Latschar, 83 F.Supp.2d at 5. The Court does not, however, owe any deference to BLM's interpretation of NEPA or CEQ regulations "because NEPA is addressed to all federal agencies and Congress did not entrust administration of NEPA to the [BLM] alone." Grand Canyon Trust v. Federal Aviation Admin., 290 F.3d 339, 342 (D.C.Cir.2002). B. NEPA Claims (Counts 1-6, 8, 12-13) Plaintiffs argue that the FEIS prepared by BLM fails in a variety of ways to comply with NEPA's requirements. Plaintiffs claim that because the Forest Service's July 2001 and August 2001 RODs amending the Manti-La Sal Forest Plan, and DOl's ROD granting Williams' ROW application all relied on the FEIS, a finding of insufficiency in the preparation of the FEIS calls into question each of these decisions. NEPA requires that all "proposals for `major federal action' `significantly affecting the quality of the environment' must be accompanied by a detailed discussion of the reasonably foreseeable effects on the environment of reasonable alternative courses of action." Taxpayers Watchdog v. Stanley, 819 F.2d 294, 298 (D.C.Cir.1987) (quoting Natural Resources Defense Council v. U.S. Nuclear Regulatory Comm'n, 606 F.2d 1261, 1269 (D.C.Cir.1979)). This requirement is "essentially procedural"; as long as the agency's decision is "fully informed" and "well-considered," it is entitled to judicial deference. Natural Resources Defense Council v. Hodel, 865 F.2d 288, 294 (D.C.Cir.1988) (quoting North Slope Borough v. Andrus, 642 F.2d 589, 599 (D.C.Cir.1980) and Izaak Walton League of America v. Marsh, 655 F.2d 346, 371 (D.C.Cir.1981)). The Court’s role is to ensure that the agency takes a “hard look” at the environmental consequences of an action, not to interject its own judgment as to the course of action to be taken. Kleppe v. Sierra Club, 427 U.S. 390, 410 & n. 21, 96 S.Ct. 2718, 49 L.Ed.2d 576 (1976); see also Nat’l Committee for the New River v. Federal Energy Regulatory Comm’n, 373 F.3d 1323, 1327 (D.C.Cir.2004) (“An environmental impact statement is reviewed to ‘ensure that the agency took a hard look at the environmental consequences of its decision to go forward with the project.’ ”). 1. Purpose and Need for the Williams Project and Consideration of No Action Alternative (Counts 2 — 4) NEPA and CEQ regulations require every EIS to consider the “purpose and need” for the proposed action. According to the regulations, “[t]he 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. Count 2 of the amended complaint asserts that BLM violated NEPA and the CEQ regulations “by approving the Williams project without properly assessing the purpose and need of the project,” in that it “failed to assess and analyze uncontradict-ed data that demonstrates that the petroleum products requirements of Salt Lake City would be satisfactorily met for the next ten years even in the absence of the Williams petroleum pipeline project.” See Am. Compl. ¶¶ 213-19. Specifically, plaintiffs claim that BLM’s consideration of the purpose and need for the project relied entirely on a December 2000 economic study undertaken by the Utah Office of Energy and Resource Planning (“UOERP”), demonstrating that the Williams pipeline would be necessary to alleviate future supply imbalances in petroleum products in the Salt Lake City market. See Am. Compl. ¶ 95. The study’s supply calculations, plaintiffs assert, failed to reflect the recent expansion of an existing pipeline from Sinclair, Wyoming to Salt Lake City or the ability of Utah refineries to expand their production capacity to meet future demand. Plaintiffs claim that an updated UOERP study reflecting this new information was presented to BLM in May 2001, and that BLM improperly ignored this new information in the preparation of the June 2001 FEIS. See id. ¶¶ 96-97. Had BLM considered this information, plaintiffs argue, it would have been forced to conclude that the Williams project was “economically infeasible.” See id. ¶ 98. The public notice and comment period for the draft EIS, however, had ended on April 16, 2001, weeks before this additional information was submitted to BLM. See Draft EIS for a Refined Petroleum Products Pipeline, Natural Gas Pipelines and Utility Corridor Analysis and Plan Amendments, 66 Fed.Reg. 11311, 11311 (Feb. 23, 2001). The Court concludes that the FEIS, released on June 1, 2001, is not defective for failing to incorporate this last-minute submission because the submission was presented after the close of the comment period. DOI, in turn, did not err in relying on the FEIS, and Count 2 of plaintiffs’ amended complaint fails. In Counts 3 and 4 of the amended complaint, plaintiffs assert that in preparing the FEIS, BLM failed adequately to discuss the “no action alternative” to constructing the Williams pipeline, and that DOI improperly failed to select it. See Am. Compl. ¶¶ 220-31; Pis’. Part. Mot. Summ. J. at 29. Plaintiffs assert that BLM was compelled to adopt this alternative because “there is no justifiable basis on which BLM could have reasonably concluded that the Williams project should succeed.” Am. Compl. ¶ 229. In addition to “specifying] the underlying purpose and need to which the agency is responding,” an agency preparing an EIS must “rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” 40 C.F.R. §§ 1502.13, 1502.14. The courts have recognized that these requirements are interrelated because “the goals of an action delimit the universe of the action’s reasonable alternatives.” Citizens Against Burlington v. Busey, 938 F.2d 190, 195 (D.C.Cir.1991). The setting of the objectives and the range of alternatives to be considered by an agency are governed by a “rule of reason.” City of Grapevine v. Dept. of Transp., 17 F.3d 1502, 1506 (D.C.Cir.1994); Citizens Against Burlington v. Busey, 938 F.2d at 195. All that NEPA requires is that the agency weigh all reasonable alternatives and come to a fully-informed decision. Davis v. Latschar, 83 F.Supp.2d at 8 (citing Strycker’s Bay Neighborhood Council v. Karlen, 444 U.S. 223, 227-28, 100 S.Ct. 497, 62 L.Ed.2d 433 (1980)). The “reasonable alternatives” an agency must consider in preparing an EIS must include the alternative of taking no action whatsoever. 40 C.F.R. § 1502.14. The purpose of discussing the “no action alternative” is “to facilitate reader comparison of the beneficial and adverse impacts of other alternatives to the applicant doing nothing.” 40 C.F.R. § 6.203(c). The Council on Environmental Quality has provided some guidance as to what the No Action Alternative discussion should include: [I]n instances involving federal decisions on proposals for projects[,] “No action” ... would mean the proposed activity would not take place, and the resulting environmental effects from taking no action would be compared with the effects of permitting the proposed activity or an alternative activity to go forward. Where a choice of “no action” by the agency would result in predictable actions by others, this consequence of the “no action” alternative should be included in the analysis. For example, if denial of permission to build a railroad to a facility would lead to construction of a road and increased truck traffic, the EIS should analyze this consequence of the “no action” alternative. Council on Environmental Quality, Forty Most Asked Questions Concerning CEQ’s National Environmental Policy Act Regulations, 46 Fed.Reg. 18026 (March 23, 1981) (pagination unavailable). BLM’s discussion of the no action alternative for the Williams pipeline proceeds by recapitulating the possible negative effects of pipeline construction and, by extension, the environmental effects that would not occur absent pipeline construction, and then concludes: Based on [the UOERP study], there appears to be a current and projected need for additional petroleum products along the Wasatch Front. If the Williams project is not constructed, deficits are predicted for diesel by the year 2013, and for gasoline, jet fuel, and all other petroleum products starting in 2001. These annual deficits would increase over time and the tbtal deficit for petroleum products would be about 10 million barrels by the year 2020. Hence, the purpose and need would not be met. See FEIS § 3.2 at 3-101. Given the FEIS's prior analysis of the project's environmental impacts, as well as its consideration of the project's "purpose and need," this discussion, while brief, lays out the costs and benefits of the no action alternative with enough specificity to allow meaningful comparison with other alternatives. No more is required. Plaintiffs' argument that DOl acted arbitrarily and capriciously by failing to select the no action alternative misconceives the nature of NEPA's m~ndate, which prescribes a process, not an outcome. Again, "NEPA's requirements are `essentially procedural'; as long as the agency's decision is `fully informed' and `well-consideredi,' it is entitled to judicial deference and a reviewing court should not substitute its own policy judgment." Natural Resources Defense Council v. Hodel, 865 F.2d at 294 (quoting North Slope Borough v. Andrus, 642 F.2d at 599); see also Strycker's Bay Neighborhood Council v. Karlen, 444 U.S. at 227, 100 S.Ct. 497; Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, 435 U.S. 519, 558, 98 S.Ct. 1197, 55 L.Ed.2d 460 (1978) ("NEPA does set forth significant substantive goals for the Nation, but its mandate to the agencies is essentially procedural."); Louisiana Ass'n of Independent Producers and Royalty Owners v. Federal Energy Regulatory Comm'n, 958 F.2d 1101, 1117 (D.C.Cir.1992). BLM's explanation of the likely effects of the Williams project, positive and negative, satisfied this procedural requirement and enabled DOT to make an informed judgment about the project. That plaintiffs disagree with the outcome of DOT's decision does not render either DOT's or BLM's conduct of the process arbitrary or capricious. 2. Consideration of Adverse Environmental Impacts (Count 5) Plaintiffs claim that the FEIS failed adequately to address a number of the Williams Project's adverse environmental effects, including the impact on watersheds along the pipeline route, the risk to communities and natural resources in the event of a landslide or earthquake, the risk of fire or explosion, and the impact of the project on sensitive plant and animal species. See Am. Compl. ¶IT 111-18, 232-38. CEQ regulations require an agency preparing an EIS to consider the "direct," "indirect," and "cumulative" impacts of a proposed action. 40 C.F.R. § 1508.25. "Effects includes ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosys~ems), aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative." 40 C.F.R. § 1508.8. Plaintiffs' claims in this respect are patently without merit, as BLM discussed each of these effects in the FEIS. See, e.g., FEIS § 3.1.5 at 3-64 to 3-70 (`Water Resources"); FEIS § 3.1.4 at 3-56 to 3-64 ("Landslide Hazards"); FEIS § 3.1.1.2 at 3-9 ("Probability of Fire"); FEIS § 3.1.6 at 3-70 to 3-78 ("Threatened, Endangered, and Sensitive Species"). Beyond the con-clusory statements in their Amended Complaint, plaintiffs give no explanation why these analyses are insufficient. Absent such an argument, the Court cannot find BLM's discussion of environmental effects in the FEIS to have violated NEPA. 3. Consideration of Socioeconomic Impact (Count 6) Plaintiffs also seek to take BLM to task for failing in the FEIS to address the socioeconomic impact of the Williams project. They claim that completion of the Williams pipeline would have a "drastic impact" on the economies of both Bloomfield and Salt Lake City, see Pis'. Part. Mot. Summ. J. at 31-32, and that it was arbitrary and capricious for BLM to complete the FEllS without consideration of these effects. See Am. Compl. ¶11 238-43. Defendants have two responses. First, NEPA requires consideration of socioeconomic factors only to the extent that "`economic or social and natural or physical environmental effects are interrelated,'" and that socioeconomic impacts unrelated to environmental effects therefore are outside the scope of NEPA. See Defs'. Opp. Part. 1V[. Summ. J. at 17 (citing Tongass Conservation Society v. Cheney, 924 F.2d 1137, 1144 (D.C.Cir.1991), and 40 C.F.R. § 1508.14). Second, I3LM did "consider[ ii potential social and economic impacts along the pipeline route," including environmental justice issues and potential effects of pipeline construction on employment, income, taxes, and local housing markets. See Defs'. Opp. Part. lvi. Summ. J. at 17-18. CEQ regulations state that "[w]hen an environmental impact statement is prepared and economic or social and natural or physical environmental effects are interrelated, then the environmental impact statement will discuss all of these effects on the human environment." 40 C.F.R. § 1508.14 (emphasis added). Nonetheless, "economic or social effects are not intended by themselves to require preparation of an environmental impact statement." Id. Only when socioeconomic effects somehow result from a project's environmental impact must they be considered. Whether an impact on the "human environment" must be addressed depends on "the closeness of the relationship between the change in the environment and the `effect' at issue." Metro. Edison Co. v. People Against Nuclear Energy, 460 U.S. 766, 771-72, 103 S.Ct. 1556, 75 L.Ed.2d 534 (1983); see also Ass'n of Pub. Agency Customers v. Bonneville Power Admin., 126 F.3d 1158, 1186 (9th Cir.1997) (agency not required to examine possible social effects of utilities being forced to pay higher stranded costs and passing those costs on to lower income consumers). The socioeconomic effects plaintiffs urge consideration of are "(i) major supply disruptions that could occur if the operation of the Williams pipeline forced closure of local Salt Lake City refineries; (ii) the impact of job losses associated with these possible closures; and (iii) the harm that could result from supply shortages if the gasoline and diesel fuel supplies on which Bloomfield currently relies were diverted to the Williams pipeline." Am. Compl. ¶ 240. There is no relationship between these economic problems and the environmental impacts of the Williams project; rather, they flow solely from Williams' proposed introduction of petroleum products into the Salt Lake City market. Indeed, these effects could easily follow even if the Williams pipeline had no environmental impacts. Consequently, they are outside the scope of NEPA, and, to the extent it declined to consider them, BLM's action was entirely reasonable. 4. Segmentation of the EIS (Count 1) Count 1 of plaintiffs' complaint asserts that BLM violated NEPA by failing to evaluate the impact of the Williams and Equilon pipeline projects in a single BIS, and that DOT acted arbitrarily and capriciously in relying on the flawed EIS in its ROD. See Am. Compi. ¶11204-12. NEPA and CEQ regulations dictate in general terms the proper scope of "actions, alternatives, and impacts to be considered in an environmental impact statement." 40 C.F.R. § 1508.25. Actions that are "similar" or "connected" or that have cumulative effects must be considered together in one EIS. 40 C.F.R. § 1508.25(a). Plaintiffs claim that because the Williams and Equilon projects are "similar" and "connected," and have "cumulatively significant environmental effects," BLM violated NEPA and CEQ regulations by deciding not to prepare an EIS considering both actions. See Motion of Plaintiffs and Plaintiffs-Intervenors for Partial Summary Judgment (March 25, 2002) ("Pls'. 1st Mot.Summ. J.") at 24-26. It is established that an agency preparing an EIS may not "segment" its analysis so as to conceal the environmental significance of the project or projects. Coalition on Sensible Transportation v. Dole, 826 F.2d 60, 68 (D.C.Cir.1987). "The purpose of this requirement is to prevent agencies from dividing one project into multiple individual actions `each of which individually has an insignificant environmental impact, but which collectively have a substantial impact.'" Natural Resources Defense Council v. Hodel, 865 F.2d at 297-98 (quoting Thomas v. Peterson, 753 F.2d 754, 758 (9th Cir.1985)); see also Taxpayers Watchdog v. Stanley, 819 F.2d at 298 (" 'Piecemealing' or 'Seginentation' allows an agency to avoid the NEPA requirement that an EIS be prepared for all major federal actions with significant environmental impacts by dividing an overall plan into component parts, each involving action with less significant environmental effects."). An agency's decision not to prepare a comprehensive EIS, like other asserted violations of NEPA, is reviewed under the "arbitrary and capricious" standard. Environmental Defense Fund v. Higginson, 655 F.2d 1244, 1247 & n. 8 (D.C.Cir.1981) (citing Kleppe v. Sierra Club, 427 U.S. at 412, 96 S.Ct. 2718 and National Wildlife Federation v. Appalachian Regional Comm'n, 677 F.2d 883, 891 (D.C.Cir.1981)) The administrative record in this case demonstrates clearly (and the parties do not dispute) that Williams and Equilon deliberately sought to segment the environmental analysis of the Aspen project so as to circumvent NEPA requirements. As they informed BLM in early 2000 (before dissolution of the Aspen partnership), it was the project proponents' expectation that if the segments were considered separately, there would be a finding of no significant impact with respect to the southern segment, allowing only an environmental assessment to be performed for that portion of the pipeline. See Jan. 2000 Steah Letter, A.R. vol. 8 at 314 ("The proponents ... would like for BLM to consider doing an EA in [New Mexico] followed by an ElS in Utah.... If only the southern part were analyzed, it is likely that there would be a finding of no significant impact determination. Because of this, the proponent would like to see it analyzed in a separate NEPA document."). BLM initially determined that the entire Aspen project needed to be analyzed in a single EIS. If the dissolution of the Aspen partnership was nothing more than a formal measure taken to avoid this requirement, and had no practical significance, it likely would have been impermissible for BLM not to have prepared a comprehensive EIS. See Natural Resources Defense Council v. Hodel, 865 F.2d at 297-98. On the other hand, if the dissolution of the Aspen partnership so changed the nature of the proposed project that the Equilon and Williams pipelines were no longer similar or connected, and no longer had any cumulative effects, then regardless of the parties’ original intent BLM might legitimately have concluded that no comprehensive EIS was necessary. Based on the administrative record, the Court concludes that plaintiffs have failed to demonstrate that the two projects have cumulative effects or are so “similar” as to require preparation of a combined EIS. The Court does find, however, that BLM acted arbitrarily in deciding, on the basis of the information in the administrative record at the time BLM prepared the FEIS, that the Equilon and Williams projects were not “connected” actions under 40 C.F.R. § 1508.25(a)(1). a. Cumulative Effects When actions “will have cumulative or synergistic environmental impact upon a region” and “are pending concurrently” before an agency, “their environmental consequences must be considered together.” Kleppe v. Sierra Club, 427 U.S. at 410, 96 S.Ct. 2718; see also 40 C.F.R. § 1508.25(a)(2). “Cumulative impacts” are those impacts “that result[] from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency ... or person undertakes such other actions.” 40 C.F.R. § 1508.7. The identification of cumulative effects is a task committed “to the special competency” of the agency preparing an EIS. Kleppe v. Sierra Club, 427 U.S. at 413, 96 S.Ct. 2718. Although plaintiffs argue that the Williams and Equilon projects have cumulative or synergistic environmental effects, they posit only one example of such an effect: the possibility that the 16-inch Equilon line will deliver enough petroleum products to allow the Williams pipeline to run at a capacity higher than 76,000 barrels per day (“bpd”), the normal flow contemplated by the FEIS. See Reply Brief of Plaintiffs and Plaintiff-Intervenors in Support of Their Summary Judgment Motion and Statement of Points and Authorities in Opposition to Summary Judgment Motions Filed by Federal Defendants and Williams Pipe Line Company, LLC (May 20, 2002) (“Pls’.Rep. 1st MotSumm. J.”) at 22-23. If the Williams pipeline were to transport a significantly greater volume of products each day, plaintiffs claim, the risk of pipeline rupture or spills would increase. Plaintiffs, however, provide no reason to expect that the Williams pipeline would experience such high throughput. The FEIS indicates that, although the Williams pipeline would be capable of transporting 100,000 bpd of petroleum products, Williams represented to BLM that “this throughput rate would occur infrequently,” and the pipeline would generally transport only 76,000 bpd. See FEIS § 2.1.1.2 at 2-7. “The starting point in any analysis of an agency’s compliance with ... NEPA is the ‘rule of reason,’ under which a federal agency proposing a major action must consider only the reasonably foreseeable environmental effects of the action.” Po tomac Alliance v. United States Nuclear Regulatory Comm’n, 682 F.2d 1030, 1035 (D.C.Cir.1982). Environmental impact statements need not address “remote and highly speculative consequences.” Deukmejian v. Nuclear Regulatory Com’n, 751 F.2d 1287, 1300 & n. 63 (D.C.Cir.1984) (quoting Trout Unlimited v. Morton, 509 F.2d 1276, 1283 (9th Cir.1974)); see also Concerned About Trident v. Rumsfeld, 555 F.2d 817, 829 (D.C.Cir.1977) (“NEPA does not mandate that every conceivable possibility which someone might dream up must be explored in an EIS.”). In this case, there is no reason to expect that the Williams pipeline would operate at a throughput higher than that proffered by Williams and contemplated in the FEIS. Absent any evidence to the contrary, the Court concludes that BLM did not act unreasonably in relying on the project proponent’s claim. Plaintiffs also attempt — unsuccessfully, in the Court’s view — to characterize other effects of the Williams and Equilon projects as “cumulative” or “synergistic” effects. For example, they characterize Williams’ possible reliance on the Equilon line as a supply source as a cumulative impact. See Pis’. 1st Mot. Summ. J. at 25. Although this reliance might demonstrate the connectedness of the two projects, and could lead to environmental impacts, it does not by itself constitute the kind of “compounded effect on the region” contemplated by the NEPA regulations, as interpreted by the Supreme Court and our court of appeals. See National Wildlife Federation v. Appalachian Regional Comm’n, 677 F.2d at 888 (citing Kleppe v. Sierra Club, 427 U.S. at 410, 96 S.Ct. 2718). It therefore is not a cumulative effect requiring analysis under NEPA and 40 C.F.R. § 1508.25. Plaintiffs further claim that synergistic effects are demonstrated by the fact that the proposed termini of the Williams and Equilon pipelines are in close proximity to each other. See Pis’. 1st Mot. Summ. J. at 25-26. BLM acknowledged this proximity in the FEIS, but dismissed the possibility that it would result in cumulative or synergistic effects, pointing out that in the area where the two pipelines would draw near, the Williams and Equilon projects involve not new pipeline construction but conversion of existing lines, and consequently that the “[s]urface disturbance effects of both projects in the area around Kunz Station, New Mexico are very small.” See FEIS Table 4-1 at 4-6. Plaintiffs have provided no reason to question the sufficiency of BLM’s conclusion in this respect. The Court therefore will not disturb the agency’s determination that the Equilon project would not result in any cumulative or synergistic effects. b. Similar Actions Plaintiffs also argue that the FEIS should have considered the effects of the Equilon project because it . and the Williams pipeline are “similar actions.” See Pis’. 1st Mot. Summ. J. at 26. “Similar actions” are those that, “when viewed with other reasonably foreseeable or proposed agency actions, have similarities that provide a basis for evaluating their environmental consequences together, such as common timing or geography.” 40 C.F.R. § 1508.25(a)(3). An agency “may wish” to prepare a programmatic EIS for any group of similar actions, but “should” do so if a programmatic EIS is “the best way” to assess their combined environmental effects. 40 C.F.R. § 1508.25(a)(3); see also Foundation on Economic Trends v. Heckler, 756 F.2d 143, 159 (D.C.Cir.1985). Plaintiffs maintain that “similar actions” must always be considered in a combined EIS, but make no attempt to demonstrate (beyond their arguments with respect to independent utility and combined effects) that doing so would be “the best way” to analyze the effects of the Williams and Equion projects. See Pis'. 1st Mot. Summ. J. at 26. Although the FEIS does not address explicitly whether the Williams and Equi-lon pipelines are "similar projects," it does establish that the two projects are on separate timelines, and that their geographic overlap is minimal. See FEIS § 1.8.2.4 at 1-30. Beyond their geographic proximity and the fact that "{t]he two projects would likely be completed within a few years at the very most"-circumstances acknowledged and discussed in the FEIS-plain-tiffs make no argument as to why the Williams and Equilon lines are similar projects. Moreover, plaintiffs make no attempt to demonstrate (beyond the arguments advanced under 40 C.F.R. § 1508.25(a)(1) and (2)) that a combined ETS would be the "best way" to assess the projects' combined environmental impacts. Absent any such argument, the Court cannot consider BLM's refusal to prepare a programmatic EIS as arbitrary and capricious under 40 C.F.R. § 1508.25(a)(3). c. Connected Actions Finally, plaintiffs claim that the Williams and Equilon pipelines are "connected actions" under 40 C.F.R. § 1508.25(a)(1), and that by refusing to consider both projects in one EIS, BLM improperly segmented its analysis. They argue that the Equilon and Williams projects were not intended to function independently but are in effect two segments of a single pipeline designed to transport petroleum products from West Texas to Salt Lake City. See Pls'. 1st Mot. Summ. J. at 15. The dissolution of the Aspen partnership, plaintiffs maintain, was a mere formality designed to allow Equilon to circumvent the NEPA review process in developing the southern segment of the pipeline, and that BLM's decision to prepare separate environmental impact statements therefore was "inexplicable and irrational." See id. Actions are "connected" or "closely related" if they: "(i) Automatically trigger other actions which may require environmental impact statements; (ii) Cannot or will not proceed unless other actions are taken previously or simultaneously; [or] (iii) Are interdependent parts of a larger action and depend on the larger action for their justification." 40 C.F.R. § 1508.25(a)(1). In determining whether an EIS has been improperly segmented to avoid consideration of connected actions, courts also have considered such factors as "whether the proposed [project] (1) has logical termini; (2) has substantial independent utility; (3) does not foreclose the opportunity to consider alternatives; and (4) does riot irretrievably commit federal funds for closely related projects." Taxpayers Watchdog v. Stanley, 819 F.2d at 298 (citing Piedmont Heights Civic Club v. Moreland, 637 F.2d 430, 439 (5th Cir.1981)). While the parties advance a variety of arguments in favor of their respective positions on whether the Williams and Equilon projects were connected actions, most focus on whether the Williams pipeline would have substantial "independent utility" regardless of whether the Equilon project ever was completed. And this, of course, is the appropriate inquiry: "The proper question [with regard to independent utility] is whether one project will serve a significant purpose even if a second related project is not built." Coalition on Sensible Transportation v. Dole, 826 F.2d at 69. Two aspects of the project's independent utility are at issue. First, plaintiffs argue that because of the limited supply of refined petroleum products in Bloomfield (besides the proposed Equion pipeline, a pipeline terminal operated by Holly Corpo- ration and a Giant Industries refinery are the only petroleum products sources in the area), the Williams pipeline cannot function without being supplied by the proposed Equilon pipeline. See Pis’. 1st Mot. Summ. J. at 16. Second, plaintiffs argue that the Williams pipeline has no independent economic utility, because even if Williams were able to obtain supplies of petroleum products in Bloomfield, the high price of those supplies would prevent Williams from selling them at a profit if they were transported to Salt Lake City. See id. at 18. Even though the parties devote a good deal of attention to the latter issue— whether the Williams pipeline would have independent economic utility in light of the petroleum products price situation in Bloomfield — the Court finds that it need not separately address that question. Plaintiffs’ argument that BLM acted arbitrarily and capriciously in concluding that the project was economically feasible is essentially the same as that advanced with regard to the purpose and need for the project, and already rejected by the Court. See supra at 240-242. Although the economic utility of the Williams project as it exists independent of the Equilon project is a slightly different inquiry, it depends entirely on whether Williams would likely be forced to rely on the Equilon pipeline for supply. The crux of plaintiffs’ argument about the independent practical utility of the Williams pipeline is that BLM’s conclusion that the Williams pipeline would have alternative sources of supply was unjustifiable because the only facts in the administrative record to support it were Williams’ unsubstantiated assurances to that effect. Plaintiffs also argue that BLM’s failure to respond adequately to EPA’s request for substantiation of Williams’ claims was itself arbitrary and capricious. In response, defendants maintain that BLM was justified in relying on Williams’ representations, and under no obligation to second-guess Williams or to investigate its claims independently. They also argue that plaintiffs accord “undue significance” to EPA’s objections to the DEIS and FEIS, that those objections were unwarranted, and, in any event, that BLM responded adequately to EPA’s comments. See Def-Intervs’. Opp. 1st Mot. Summ. J. at 27-28. On the facts established by the record in this case — including Williams’ own statements to BLM and representations made by two potential suppliers, EPA’s comments on the issue of Williams’ source of supply, and other circumstances that should have given BLM reason to doubt Williams’ representations — the Court concludes that BLM’s finding of independent utility was unsupportable. While Williams originally had applied to BLM for a pipeline ROW allowing it to construct only the northern segment of a pipeline to Salt Lake City, in February 1999 Williams and Equilon formed the Aspen partnership, which subsequently was designated the project proponent for a pipeline running all the way from Odessa, Texas to Salt Lake City. See Def-In-tervs’. Opp. 1st Mot. Summ. J. at 3^1. The partners explicitly informed BLM that if the agency decided to prepare a single, comprehensive EIS for the entire project, the Aspen partnership would be dissolved and the two companies would develop the northern and southern segments of the pipeline independently. See Letter from LaVerne Steah to Sally Wisely (Jan. 6, 2000) (“Jan.2000 Steah Letter”), A.R. vol. 8 at 314-15. Nonetheless, BLM determined that it would prepare a single, programmatic EIS for the entire pipeline. See Feb. 2000 Wisely Letter, A.R. vol. 8 at 449. After BLM announced its decision, Williams and Equilon dissolved the Aspen joint venture. Williams filed an amended ROW application in its own name for a pipeline starting in Bloomfield, claiming that Williams would “no longer include Equilon’s proposed pipeline as an alternative source of supply” for its line, and requesting that its ROW application be reviewed independently of any ROW application filed by Equilon. See Mar. 2000 Powell Letter, A.R. vol. 8 at 451. Although BLM considered preparing a single EIS for the entire pipeline even after Williams and Equilon filed their separate ROW applications, BLM published in the Federal Register a notice of intent to proceed with an EIS encompassing only the Williams, Questar, and Kern River pipelines. 65 Fed.Reg. 21006 (April 19, 2000). Thereafter, Equilon filed an amended ROW application for its segment of the pipeline, proposed to extend from Odessa to Bloomfield. See Pis’. Facts ¶ 18; see also Letter from Daniel J. Ner-bonne, Equilon Pipeline Company LLC, to Ron Montagna, BLM (March 10, 2000), A.R. vol. 8 at 176. BLM’s decision to consider the Williams and Equilon projects independently was predicated largely on the dissolution of the Aspen partnership and Williams’ assurances that it no longer would rely on Equi-lon t