General
USCCB Letter to the Council on Environmental Quality regarding Regulations Implementing the Procedural Provisions of the National Environmental Policy Act (2020)
Comments on the Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act, March 10, 2020
On behalf of the United States Conference of Catholic Bishops (USCCB), we submit the following comments on the proposed Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA). 85 Fed. Reg. 1684 (Jan. 10, 2020).
The established purpose of NEPA is to “create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans.”1 These principles are closely aligned with Catholic social teaching, wherein integral human development is “marked by solidarity and inter-generational justice, while taking into account a variety of contexts: ecological, juridical, economic, political and cultural.”2 In many ways, NEPA gives concrete expression to principles of integral ecology and compels the federal government to care for the common good through environmental stewardship.
The stated goals of the Update to the Regulations Implementing the Procedural Provisions of NEPA are to “modernize and clarify the CEQ regulations to facilitate more efficient, effective, and timely NEPA reviews by Federal agencies.” 85 Fed. Reg. at 1684. While modernization, efficiency and timeliness are laudable goals, they should be implemented in a manner that still advances, and does not undermine, NEPA’s mission “of restoring and maintaining environmental quality.” The rule fails to demonstrate how the proposed updates will advance that mission.
For the reasons stated here, we ask the CEQ to reverse its determination to remove cumulative effects analyses and to maintain an approach to environmental protection which includes reasonable consideration of climate change. The CEQ must also give appropriate consideration to the role of continuity in maintaining environmental policies that foster a prudent use of natural resources. Therefore, we urge the CEQ to withdraw its Update to the Regulations Implementing the Procedural Provisions of NEPA.