Comments on: National Environmental Policy Act Implementing Regulations Revisions

The New Jersey Environmental Justice Alliance (NJEJA) would like to submit the following comments to the Council on Environmental Quality (CEQ) concerning its recently released National Environmental Policy Act (NEPA) Implementing Regulations Revisions. In March of 2020 NJEJA submitted comments on CEQ’s proposed changes to the regulations that implement procedural provisions of the National Environmental Policy Act (Docket ID No. CEQ-2019-0003, Notice of Proposed Rulemaking, 40 CFR Parts 1500, 1501, 1502, 1503, 1504, 1505, 1506, 1507, and 1508). Those comments focused on, and strongly disagreed with, CEQ’s proposal to remove the requirement to perform cumulative impacts analyses in environmental review documents created pursuant to NEPA. Because it is such an important issue to environmental justice (EJ) residential communities and to the EJ advocacy community these comments similarly focus on whether cumulative impacts analyses should be a required part of NEPA reviews. NJEJA believes they should be.