In a letter to the Chair of the Council on Environmental Quality (CEQ), ARTBA offered the following comments on the proposed National Environmental Policy Act (NEPA) Phase 2 rule:

  • CEQ’s proposal is outside the bounds of the NEPA statute and must be rescinded.
  • NEPA is a procedural statute that is not meant to drive any particular outcome.
  • The rule is unenforceable and would result in costly litigation and project delays.
  • CEQ must account for the real-world impacts of delays in its proposal.

 

Topic

Advocacy, Environmental, Regulatory & Legal

Resource Type

Comment Letter

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