RDC comments on NEPA revisions, Docket ID: CEQ-2021-0002

November 22, 2021

Brenda Mallory, Chair 
Council on Environmental Quality 
Docket CEQ-2021-0002 
730 Jackson Place NW 
Washington, DC 20503 


Submitted via regulations.gov/docket/CEQ-2021-0002 

RE: CEQ request for revisions to NEPA Process, Docket # CEQ-2021-0002

Dear Chair Mallory:

The Resource Development Council for Alaska, Inc. (RDC) is writing in response to the Council on Environmental Quality’s (CEQ) request for comments on proposed revisions to the regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA), Docket ID: CEQ-2021-0002.

RDC is a statewide trade association comprised of individuals and companies from Alaska’s fishing, forestry, mining, oil and gas, and tourism industries. RDC’s membership includes Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources. 

RDC urges extreme caution in making changes to the NEPA implementing regulations and encourage the CEQ to work with project developers and industry groups in drafting these changes – ensuring to not add additional levels of bureaucracy with little to no added benefit to the environment. Such actions would send the wrong message to community and project developers, especially in a state that lacks community access and infrastructure. 

RDC appreciates the CEQ’s efforts to streamline the NEPA review process, reduce unnecessary regulatory burdens, and clarify longstanding CEQ regulations. Further, as stated by the CEQ, it has issued numerous guidance documents but has amended its regulations substantively only once.

It is a policy of RDC to advocate for predictable, timely, and efficient state and federal permitting processes based on sound science and economic feasibility. RDC believes the current rule sets forth process and content requirements to guide the development, amendment, and revision of NEPA. RDC members view this rule as an excellent opportunity to fix the broken or often-misused NEPA process, using a federally streamlined, science-based process.

Thank you for the opportunity to comment on potential revisions to update and clarify the NEPA process. We look forward to working with the CEQ to improve the efficiency of the NEPA process.

Resource Development Council for Alaska, Inc.