Oppose the NPRM by signing this petition which will be entered into the public record prior to the March public comment closing date.  At just over 6 pages in length, the National Environmental Policy Act is one of the greatest pieces of federal legislation ever enacted.  Caldwell’s work was a gift to a first world western society.  Unfortunately, it is also one of the most misunderstood pieces of legislation created and consumptive economic powers in this country have spent the last 50 years trying to tear down something magnificent instead of trying to follow it well. IMAGINE, instead, if we had spent the last 50 years just trying to follow the policy better each time; a policy that gives decision makers and project designers an easy-to-follow repeatable process leading to defensible project decisions each and every time.  NEPA is based on a simple and beautiful premise – let’s make sure we consider how our actions today affect our kids and grandkids and their futures.  It says, in essence, think before you act!  IMAGINE THAT!  NEPA values critical thinking and in its purest form, it asks decision makers to be informed, timely, and objective when making decisions about projects moving forward.  It aspires decision makers to strive to make projects a part of the human, physical, and natural communities instead of a part from the communities. When Nixon signed the law into history, he said it would help "America pays its debt to the past by reclaiming the purity of its air, its waters, and our living environment." NEPA was created in direct response to years of preventable environmental disasters caused by those exact same industries that now support this NPRM.  In other words, there is NO OBJECTIVITY in this NPRM; it is completed biased AGAINST the environment.

This petition is to direct CEQ to withdraw ALL proposed rulemaking as published on January 10, 2020 (and further, any proposed by this or any Trump administration).  According to the publication, CEQ is “…proposing to update its regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA). CEQ has not comprehensively updated its regulations since their promulgation in 1978, more than four decades ago. This proposed rule would modernize and clarify the regulations to facilitate more efficient, effective, and timely NEPA reviews by Federal agencies in connection with proposals for agency action…”  Make NO mistake, the proposed rulemaking (NPRM) is rooted in ulterior motive and false claims.  In short, the NPRM would be catastrophic and would lead this country back to the dark ages of civil thought – never mind how damaging these rules would be to the environment.  And let’s be 100% clear, for every claim made by the now biased and unobjective CEQ (for example, Mary B. Neumayr, now Chairperson of CEQ as appointed by Trump, clearly has constrained and limited views on environmental law) about the alleged benefits of the rulemaking, countless studies completed by respected scientists and institutions exist that would counter those conclusions.

Is NEPA perfect?  No.  But no law is; however, it is undeniable NEPA has led to countless societal benefits across the United States... and much better projects as its result.  NEPA is considered the magna carta of environmental law; if it were such a problematic law, why would over 80 other countries adopt environmental policy that mimics NEPA?  Imitation is the best form of flattery. 

A primary foundational argument for NPRM is that projects take too long and adversely affect the economy because of NEPA.  The logic is 100% incorrect.  First, near 97% of federal actions (hence, projects) are EXEMPT from NEPA.  97%!!!  Second, for those actions subject to the law, study after study show delays occuring while NEPA is underway are more often the result of some agency action that happens outside of the NEPA process (and hence causes it to slow down).  And third, Environmental Impact Statements (EISs), the most complex of NEPA processes, occur for less than one percent of all proposed federal and commercial actions. These rarities happen when the project being proposed has the real potential to have significant adverse effects on the human, physical, and/or natural environment.  The average time frame to complete an EIS is 5.5 years.  In the 1970s, an arbitrary decision was that an EIS should take 3 years.  Hence, the now common outcry that it takes too long.  BUT, 1) one must account for the fact that 5.5 years is most often NOT the result of NEPA as noted above; and 2) so what?  It takes 5.5 years to undergo a process that informs decision making, allows the public to weigh in, looks at alternatives and attempts to understand how a major project will affect 100,000s/even millions of people for the following 100 years... and 5.5 years is too long?  5.5 years is too long to critically and objectively think about these potential adversities; about how these adversities might affect your kids and grandkids?  Should this take less time?  Some studies say yes, some say NEPA is not the cause.  Regardless, IMAGINE, as noted above, the last 50 years was spent on just doing it better instead of trying to tear it down?  The advances that have been missed because of that shortsightedness..

The general claim is these updates are needed to protect the environment, create jobs and unlock investment.  First, deregulation as proposed under these “updates” will only hurt the environment and many agree.  Second, the claim infers that NEPA has limited job creation and adversely affected the American economy.  Right now, the Trump administration claims we are in the greatest economic conditions ever experienced and more jobs are being created everyday!  THIS is the most evident of falsified claims for the proposed rulemaking.  Quite arguably, the proposed changes will lead to job loss!!

Let us be clear in understanding the logic for this rulemaking by starting with who supports this NPRM.  They are:  Airlines for America, American Chemistry Council, American Coke and Coal Chemicals Institute, American Council of Engineering Companies, American Farm Bureau Federation, American Fuel & Petrochemical Manufacturers, American Forest & Paper Association, American Gas Association, American Highway Users Alliance, American Iron and Steel Institute, American Petroleum Institute, American Public Power Association, American Road & Transportation Builders Association, American Trucking Association, Associated Builders and Contractors, Associated General Contractors of America, Association of American Railroads, Association of Oil Pipe Lines, Edison Electric Institute, Federal Forest Resource Coalition, Independent Petroleum Association of America, International Liquid Terminals Association, National Asphalt Pavement Association, National Association of Home Builders, National Association of Manufacturers, National Association of Realtors, National Lime Association, National Mining Association, National Rural Electric Cooperative Association, Portland Cement Association, The Fertilizer Institute, The National Stone, Sand, & Gravel Association, Treated Wood Council, and the U.S. Chamber of Commerce.  THESE ORGANIZATIONS REPRESENT THE EXACT INDUSTRIES THAT CAUSED THE CATASTROPHIC POLLUTION IN THE 1950s and 1960s; WHAT MAKES ANY SANE PERSON THINK FOR ONE MOMENT THAT THESE INDUSTRIES ARE MORE RESPONSIBLE TODAY THAN THEY WERE THEN?  IF ANYTHING, THESE INDUSTRIES ARE LESS RESPONSIBLE TODAY.  GIVEN THE CHOICE, EACH AND EVERY TIME, THESE INDUSTRIES WILL DO THE MINIMUM NECESSARY DESPITE THE FUTURE HARM IN ORDER TO MAXIMIZE PROFIT.  NOW MORE THAN EVER.  THERE IS ABSOLUTELY NOTHING IN WESTERN SOCIETY'S CONSUMPTIVE FOR-PROFIT CULTURE THAT HAS CHANGED SINCE 1970 TO SUGGEST BEHAVIORS WOULD BE DIFFERENT.  Further, is there one community organization, one environmental group, one social organization on this list of NPRM supporters?  NO!!!

Let’s be honest.  The proposed rulemaking is being directed by a developer who now sits in the White House who wants to get back at every agency and every law that he feels slighted him from building what he wanted or made him pay money to someone whom he didn’t want to pay (it’s already been proven he regularly failed to pay contractors during his time as an alleged responsible developer).  It’s clear too that it is his chief goal to remove from the history books any legacy from the previous administration; consequently, the environment will pay for that petty vendetta.  These proposed changes will also LIMIT YOUR VOICE on projects near where each of you live…

America, it is time to step up to this one-sided and dangerous agenda the current administration presents on the environment.  Trump and his administration have extensively accelerated environmental deregulation.  Scientific experts, including members of the EPA's own scientific advisory board, have asserted the deregulatory nature of the NPRM to the NEPA legislation as proposed will be detrimental toward the environment; and therefore, detrimental to us. For those not born or who can remember before 1970, in this country, at that time, industrial pollution flowed freely in America’s waters, waterways were dead and poisoned (creeks would be green one day, red the next, orange the next... but never clear) and some regularly caught on fire, birds fell out of the sky from the poison ingested or from the acid rain that was killing forests throughout the eastern U.S., massive hazardous waste dump sites were being discovered across the U.S. (put there by those same industries supported by the associations listed above; and let’s be honest, they have not learned a single lesson).  Not a single sane person should want this again.  EVER. At that time, we didn't fully understand how large-scale environmental destruction happens and how to stop it.  Frankly, we still don’t; today's environmental catastrophes include dead zones in Chesapeake Bay, the Gulf, and Sea of Cortez, the Exxon Valdez, Deepwater Horizon, Chernobyl, massive islands of plastic in the Pacific Ocean killing off countless animals everyday, species extinction rates far exceeding any of the last five extinction periods in geological time, and sea level rise that is costing our economy countless billions of dollars. 

If anything, we need more responsible protections today than we did in 1970.  And yet, this NPRM under the Trump administration is taking us exactly to this place and will dismantle decades of environmental protections. The NPRM fails at all levels to recognize the social justice (justice for natural resources, human resources, physical resources) NEPA intended to bring to a civilized world.  It, instead, proposes a permanently dangerous, irreversible and ignorant path towards an inequality demonstrative of partial representation.  Oppose the NPRM by signing this petition which will entered into the public record prior to the March public comment closing date.