Comments re CEQ-2021-0002, NPRM, NEPA Implementing Regulations Revisions

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Dear Chair Mallory,

Thank you for the opportunity to submit comments on the Council on Environmental Quality’s (CEQ) proposed Update to the Regulations Implementing the Provisions of the National Environmental Policy Act (NEPA).1 On behalf of our members, representing mining impacted communities throughout the United States, we urge you to rescind the 2020 NEPA rules,2 reinstate the 1978 rules3, and improve upon them in the second round of rulemaking.

We appreciate CEQ’s proposal to restore NEPA’s indirect and cumulative review. This kind of review is integral to understanding how mining affects the climate and communities and the natural resources they depend upon. Indirect and cumulative impact reviews must be thorough in scope, both in terms of geography and time.