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For the legal definition of "frivolous", yes. For stuff like asking for additional EPA assessments which change nothing, but add another year and cost $$$, not so much.

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You are assuming that you know the outcome of the assessment then. But that isn't always the case.

If you look at the outcomes of the assessments, they add zero value. They are intentionally designed to waste time and money.

As an example, the nuclear storage facility was delayed, and ultimately cancelled, because the geologic analysis had only established the stability of the ground for the next 800,000 years, and the lawsuit demanded that it be extended to several MILLION years into the future. ...and they WON.

Absolute INSANITY.

No, NEPA only requires you to gather the environmental impact data. There is no obligation to act on it in any way. It commonly gets used to request for more data to be gathered and delay projects further and use this as a bargaining chip or to sink the project entirely by creating costs for the project owner.

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