CP causes info overload --- impact is mass delays and say “no”

Information overload for decisionmakers. -   To the extent that critical, rational dialogue does occur among participants during the NEPA's EIS process, the heavy scientific jargon that dominates the process makes it difficult for ordinary citizens to engage in meaningful dialogue about an EIS's substance. It has been observed that most citizen participation in the EIS process occurs through interest groups. Although interest group participation does not impair the quality of the decisionmaking process, it makes citizen interaction less likely. This, in turn, makes it more likely that interaction, to the extent it occurs, is confined to those who are the primary conveyors of scientific information - agency and nonagency experts, or powerful interest groups who can afford to finance their own scientific research. Thus, to the extent the process is expertise-intensive, it may raise some problems for pluralist decisionmaking, which values political bargaining over scientific dialogue.  [*226]  The EIS process also may interfere with the operation of expertocratic and deliberative democracy decisionmaking models. Expertocratic models may suffer because often the rationality of the analysis that occurs in the EIS process is thwarted by too much information. Agency decisionmakers, like individuals generally, face a "scarcity of attention." Although additional information is often helpful, sometimes it can change how a phenomenon is perceived and evaluated. Too much information is also likely to invite agency decisionmakers more readily to "satisfice" - to "look for good enough solutions rather than insisting that only the best solutions will do." As agency decisionmakers increase their usage of heuristic devices or shortcuts, rather than attempt to develop complete and accurate analytical tools, they also increase the potential for error in their decisions. Thus, in the absence of limitations on the amount of information, decisionmakers suffer information overload and are forced to simplify their models, thwarting their ability to engage in complete and accurate rational analysis. Information overload may also give rise to operational problems for the deliberative democracy decisionmaking model. Lay citizens sometimes participate fully in the EIS process, although, when they do so, decisionmakers often tend to ignore their comments. To the extent that participants provide information during the EIS process, however, they often do so in a manner that discourages civic discussion of values. According to one commentator, "most comment letters from private individuals are either emotional expressions of personal preferences or form letters with the same content but different signatures." Moreover, the expertise-laden format of the EIS may lead agency decisionmakers to view themselves primarily as [*227]  facilitating the objective transfer of information, rather than choosing fundamental values or assessing the quality or integrity of the information exchanged. b.   Opportunities for strategic behavior on behalf of participants. -   Additional information provided by participation may confer political advantages on participants, creating additional opportunities for lay participants to act strategically in the process. While this is probably not fatal to pluralist decisionmaking cultures, it can raise problems for expertocratic and deliberative democracy models. Large-scale participation may facilitate strategic or irrational behavior by participants, rather than civic discussion among them. For example, in evaluating the environmental impact of a proposed decision, such as building a road through a heavily forested area, conservationists may generate information about endangered populations and environmental risks. While such information may be helpful to decisionmakers, it may also increase the support for conservation by mobilizing participants who value knowledge of what may be jeopardized by resource exploitation. For example, such information may induce active participation in the process by the pharmaceutical industry in protecting sources of biodiversity. Thus, credible and well-disseminated information may increase awareness of risks among participants and the political pressure of mobilized interests. However, enhanced awareness of risks and mobilization of interest groups will not always contribute to rational decisionmaking or benefit the deliberative process. Rather than promoting dialogue and movement toward consensus, additional information may have the effect of increasing the divergence between participants' preferences and interests, or further entrenching preexisting preferences and interests, as participants are encouraged to join predefined factions. For example, knowledge that a forest has precisely six million significant plant and animal species and two [*228]  million cubic meters of marketable timber does not draw those concerned with biodiversity any closer to those concerned with timber as an economic resource. It has been observed that, in the context of analysis of forestry data, "the net effect of the information and valuation effort may be to polarize the positions, without contributing greater responsibility, balance, or consensus to the formulation of resource management policy." EIS hearings with large numbers of participants have been described as "meaningless displays of ideological fervor that have no impact on policy or implementation." By facilitating strategic action by participants, such as additional delay and the obfuscation of issues, such information may work to take additional agency time and resources without necessarily improving the rationality of the final agency decision or the deliberative quality of the decisionmaking process. Ultimately, delay may have the effect of killing proposed projects or agency programs.