June 23, 2020
| The Honorable Nita Lowey Chairwoman Committee on Appropriations House of Representatives Washington, D.C. 20515 | The Honorable Betty McCollum Chair Subcommittee on Interior, Environment and Related Agencies House of Representatives Washington, D.C. 20515 |
Dear Chairwoman Lowey and Chair McCollum,
We are writing on behalf of over 1,800 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 (NPS). The Coalition studies, educates, speaks, and acts for the preservation of America’s national park system. As a group, we collectively represent over 40,000 years of experience managing and protecting America’s most precious and important natural and historic resources. Among our members are former NPS directors, regional directors, superintendents, resource specialists, rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
On June 4, 2020, President Trump issued Executive Order 13927, Accelerating the Nation’s Economic Recovery from the COVID-19 Emergency by Expediting Infrastructure Investments and Other Activities, to direct “…the Secretary of the Interior…(to) use all relevant emergency and other authorities to expedite work on, and completion of, all authorized and appropriated infrastructure, energy, environmental, and natural resources projects on federal lands…”. To accomplish this work, the EO states that “…the heads of all federal agencies are directed to use, to the fullest extent possible and consistent with applicable law, emergency procedures, statutory exemptions, categorical exclusions, analyses that have already been completed, and concise and focused analyses, consistent with NEPA, CEQ’s NEPA regulations, and agencies’ NEPA procedures.”
The Coalition is strongly opposed to this executive order’s broad implications. Months ago, the administration proposed sweeping changes to the way federal agencies comply with NEPA. We submitted extensive comments to the CEQ and testified in two public hearings that the proposed changes would have serious and detrimental impacts to the way NPS plans for projects and involves the public in decision-making.
Now, NEPA is again under attack from this administration under the guise of the pandemic crisis, further jeopardizing the continued protection of national parks.
The current CEQ regulations already allow for “alternative arrangements” when agencies face natural disasters, such as fire, flooding, chemical spills, and earthquakes. In such a case, a federal agency consults with CEQ to determine a course of action and to decide whether or not a situation requires an immediate response without preparing an Environmental Impact Statement or an Environmental Assessment. However, the long-term disaster response and the recovery actions remain subject to the regular NEPA process.
The President’s recent executive order is not only unnecessary, it represents a real threat to our national parks. It means that ongoing projects may be considered “an emergency” simply for economic emergency reasons. And national parks are already vulnerable to proposed large-scale infrastructure projects that can impact the irreplaceable natural and cultural resources that parks exist to protect.
We urge you to consider including language in the Fiscal Year 2021 Interior, Environment, and Related Agencies appropriations bill that would prohibit the use of any federal funds to implement Executive Order 13927 issued on June 4, 2020 on national parks and other public lands.
While the Coalition supports an appropriate emergency response to the pandemic, as well as a stable workforce and economy, we do not agree that our parks should be sacrificed for the broadly described perceived “emergencies” envisioned by this executive order. We hope you will consider our concerns as you work on the FY 21 appropriations bills.
Sincerely,
Phil Francis
Chair, Coalition to Protect America’s National Parks