← League of Women Voters
CEQRulemakingCEQ-2019-0003

Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act

RIN
—
Last modified
May 21, 2024
Comment window
closed 2331d ago
League of Women Voters filings
3

Activity

League of Women Voters filed 3 comments on this docket between Mar 10, 2020 and Mar 11, 2020. 336 other organizations filed here. The comment window closed 2331d ago.

What League of Women Voters filed (3)

Mar 11, 2020· Comment from Nancy Hedinger, League of Women Voters of New Jersey· CEQ-2019-0003-159458

Federal Register/Vol 85 No 7, Friday January 10, 2020, Proposed Rules The League of Women Voters of New Jersey (LWVNJ) is submitting the following comments regarding the above Register proposed rules. The League of Women Voters is not an environmental organization, we are a public interest organization whose mission is to inform and educate citizens in government. However, when there is an issue of national importance such as the effort by the current administration to remove all protections from our rivers, open spaces, and previously protected areas, we believe LWVNJ has a role. New Jersey is the most densely populated state in the nation, with several federally protected areas, both aquifer and marshlands. We cannot afford any reduction in protections from our fragile areas. These "improvements" to the National Environmental Protection Act (NEPA) will cause serious damage to our State. It appears from reading both the summary and text of the proposal that part of the goal makes sense: updating to the paperless world and faster communications. However, to equate "efficiency" with protection of the environment is faulty. Reducing the comment period for reviews by agencies will necessarily reduce the opportunity for public input, which is neither in keeping with the intent of the National Environmental Policy Act nor in the best interest of the public. We applaud the agency for the proposed inclusion of tribal agencies in any review procedure. For too long, these agencies have been excluded in decisions directly affecting their natural resources. However, our main objection is the proposal to narrow the range of alternatives to the proposed actions. (40 CFR 1505.5) The agency now describes "existing conditions, projected future conditions, and statutory obligations and authorities that may relate to the proposed agency action..." But now the agencies will examine "a narrower range of alternatives"; when the project has significant impact, "the agency should consider reasonable alternatives that would avoid these impacts or otherwise mitigate those impacts to less than significant levels". More disturbing is the fact that agencies "should focus on analyzing material effects and alternatives, rather than marginal details that may unnecessarily delay the environmental review process". With the current administration reducing protections for birds, protected lands, wildlife and our waterways, who will determine "marginal detail"? The fact sheet (p,2) states that this new rule will Simplify the definition of environmental "effects" (their quotation marks) and clarify that effects must be reasonable foreseeable and have a reasonable close causal relationship to the proposed action and further that "reasonable alternatives" (their quotation marks) requiring consideration must be technically and economically feasible. We find this most disturbing in light of our current administration's priorities. To conclude, the LWVNJ opposes several of the proposals for NEPA, one of the most far reaching environmental rules in history. National Environmental Policy Act is the "Foster Parent" of the Clean Water Act, the Clean Air Act, the Safe Drinking Water Act and other major pollution control laws designed to protect our environment and public health. Now is not the time to weaken its effectiveness under the guise of "efficiency".

View on regulations.gov →
Mar 11, 2020· Comment from Jessica Jones Capparell, League of Women Voters of the United States· CEQ-2019-0003-167325

Please see attached comments from the League of Women Voters of the United States.

View on regulations.gov →
Mar 10, 2020· Comment from Sonya Pennock, League of Women Voters· CEQ-2019-0003-81517

Comments on: : Docket ID: CEQ-2019-0003 -Update on Regulations Implementing the Procedural Provisions of the National Environmental Policy Act. While NEPA may need some revisions to streamline the process, this proposal is awful! It effectively eliminates the main purpose of NEPA--to identify all potential environmental harms that may result from a proposed major federal project and facilitate public participation in the process of evaluating the risks and potential options for mitigating environmental damage. Here are specific problems with the proposal: Eliminating the consideration of indirect and cumulative environmental impacts prevents the assessment of what might be the most damaging environmental impacts of a project. If this change is adopted, long-term, wide-spread impacts such as release of greenhouse gases would not need to be considered. The statute requires broadly that the environmental consequences of a project must be identified. To limit what harms may be considered is to nullify part of NEPA. It also would distort infrastructure planning by making it easier to ignore predictable futures like, for example, increased wide-spread flooding that could severely degrade a project. The proposed changes exempting certain projects are vague and could result in wide-spread exclusions of projects from NEPA review. For example, the revisions do not identify the threshold for federal funding that would trigger NEPA. Also, exempting projects that conflict with other laws could be read to exempt all projects that might be tied to Federal legislation or Presidential fiat. This is a huge loophole! The proposal should specify which projects would receive exemptions so that the public can weigh in on these exemptions. One of the major purposes of NEPA is to involve the public in the process of considering the impacts of a project on the environment. The proposed changes would cut out citizens and local governments whose comments focused on general concerns about the environmental impacts. To only consider significant those comments with a specific scientific or technical basis is to negate one of the most important functions of NEPA. In addition, the proposed rule will increase costs to those who want to comment on or challenge a draft EIS this eliminating involvement of those who can't afford to "pay to play." Limiting opportunities for judicial review and prohibiting challenges to the analyses is short-sighted. Disallowing arguments based on issues that were not raised during the public comment period would prevent citizens, local governments and others from bringing up new information that would be relevant to determining the environmental impacts of a project or possible ways to reduce those harms. An arbitrary two-year limit on the EIS process may result in inadequate evaluation of the environmental damage posed by some projects and will short change the public participation process. Please end this effort to prevent adequate study of environmental impacts and rollback public participation.

View on regulations.gov →

Abstract

No abstract recorded.

View on regulations.gov →

Co-filers (336)

See everyone who commented →