TWS comments on proposed NEPA changes

The Wildlife Society, along with other professional societies, recently expressed concerns that some proposed changes to the National Environmental Policy Act could have serious effects on natural resources and asked them to be withdrawn.

They Society joined with nine other professional societies, representing more than 35,000 individuals with diverse expertise in natural resource sciences, to comment on proposed changes to regulations for implementing NEPA. The proposed changes could limit the extent of environmental analysis and the number of situations that require environmental analysis under NEPA, and therefore have serious effects on natural resources.

“The proposed changes would arbitrarily limit the geographic and temporal scope of environmental reviews, shift the burden of assessing the adequacy of alternatives considered from the agency to the public, remove the original environmental protection purpose of the Act, ignore the interconnectedness of environmental processes, and fail to consider the long-term implications of federal decisions,” the letter reads.

The changes were proposed in early January by the Council for Environmental Quality, which oversees NEPA implementation, and would reduce the situations in which environmental review is required, place page limits and deadlines on reviews, and limit the kinds of possible effects that would have to be considered, among other changes.

The letter stresses the foundational role that NEPA plays in ensuring that federal decisions are thorough and consider all possible effects on natural resources.

The involved societies are particularly concerned about the proposal to change the definition of “effects or impacts” so that it no longer includes indirect effects or impacts. The proposal would also eliminate the requirement to analyze cumulative effects of an action, which could have long-lasting repercussions on the ability of natural resource professionals to plan and mitigate for system-level changes that a project may put into motion.

The letter asks the CEQ to reconsider many of the proposed changes and recommends that “any changes to the regulations that currently implement NEPA should … ensure that environmental reviews continue to appropriately analyze proposed federal actions for their impacts to natural resources.”