“The White House Council on Environmental Quality’s (CEQ) January 2020 proposal to revise its regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA) prompted more than 172,000 public comments.
Our article summarizes the proposal. Below, we provide excerpts from detailed comments on those proposed provisions from organizations that either support or oppose the CEQ’s action.
Indirect and Cumulative Effects
“Cumulative and indirect effects consideration has been a fundamental part of the NEPA process since its inception. Not coincidentally, this is also the major basis for NEPA challenges regarding climate change issues, the body of which have recognized that analysis of climate change, an indirect and cumulative effect, is required by the statute.”
—Public Employees for Environmental Responsibility”