January 20, 2020

Mary Neumayr, Chair
Council on Environmental Quality
730 Jackson Place, N.W.
Washington, DC  20503

Edward Boling, Associate Director for the National Environmental Policy Act
Council on Environmental Quality
730 Jackson Place, N.W.
Washington, DC  20503

Subject:  Request for a 60 day Extension of Public Comment Period on “Update to the Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA)”
{Docket No. CEQ-2019-0003}

Dear Council on Environmental Quality:

I am writing to you on behalf of over 1,700 members of the Coalition to Protect America’s National Parks (Coalition), a non-profit organization composed of retired, former, or current employees of the National Park Service. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. As a group we collectively represent nearly 40,000 years of experience managing and protecting America’s most precious and important natural and historic resources. Among our members are former directors, regional directors, superintendents, environmental and resource specialists, rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

On behalf of our members, I am requesting a 60 day extension of the public comment period for the recently published Notice of Proposed Rulemaking (NPRM) on the “Update to the Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act,” Docket No. CEQ-2019-0003.

This NPRM proposes sweeping changes to the entirety of regulations implementing NEPA across all federal agencies, including the National Park Service. Over the past 50 years national park managers, including many of our members, have utilized NEPA for a multitude of projects ranging from infrastructure improvement, wildlife management, facility development and general management planning. Among other things, the current NEPA process ensures that there is science-based analysis, evaluation of a range of reasonable alternatives and their impacts, and structured opportunities for public involvement. This process has proven to be instrumental to informing decision makers as well as the public of what consequences may occur through implementation of proposed actions. Our experience has been that adherence to the process inevitably leads to better planning, meaningful mitigation measures and, ultimately, a better project.

In brief, the current NEPA implementing process has been a critical mechanism for ensuring the National Park Service fulfills its statutory mission, which is to “….to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” 54 U.S.C. § 100101. Frankly, we are very concerned that this proposal will fundamentally change, in essence undermine, the way federal agencies, including the National Park Service, consider and plan for actions that are likely to impact the environment.

The two-page Advanced Notice of Public Rulemaking (ANPR), which the Coalition responded to, allowed for a 60 day comment period and simply posed a series of questions regarding NEPA reform. In contrast, the 47-page NPRM proposes highly complex revisions having legislative and judicial ramifications, yet it too allows only 60 days of comment. It is important to the Coalition to assess CEQ’s response to public and agency comments on the ANPR as they relate to national parks. In addition, we request extra time to evaluate and comment on the proposed regulatory changes and implications for cultural and natural resource management of parks in both the short and long term. Given the importance of the NEPA implementing regulations to the conservation of national park resources and values, CEQ’s proposed 60 day comment period is not an adequate or reasonable amount of time for thoughtful and meaningful response to the NPRM.

We also note that CEQ plans to hold only two public hearings in Denver and Washington, DC. Given that there are currently 419 park units of the National Park System covering the expanse of the United States and many of its territories, two hearings are simply not sufficient to reasonably engage the public with regard to the proposed regulations’ potential impacts on park resources. We request that public hearings also be conducted in other cities where NPS regional offices reside, such as Atlanta, Seattle, San Francisco, and Anchorage, Alaska.

Our request for an additional 60 days would accommodate additional public hearings as well as allow the Coalition and other interested parties to adequately assess the implications of the proposed CEQ revised regulations on resources and values of the National Park System.

We would greatly appreciate your thoughtful consideration of our request.





Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
201 I Street, NE #805
Washington, DC 20002