November 22, 2021 \u2013 Today, the Clinic submitted comments to the Council on Environmental Quality (CEQ) supporting its proposed partial reversal of the Trump administration\u2019s weakening of the National Environmental Policy Act (NEPA) implementing regulations.\u00a0 The Clinic\u2019s comments argue that agencies are required under NEPA to examine cumulative and indirect impacts (as well as direct effects) when determining the environmental impacts of a project and preparing an Environmental Impact Statement (EIS). \u00a0Accordingly, the Trump administration\u2019s elimination of these categories of impacts from the regulations was illegal and the proposal is correct to reverse those changes. In addition, the Clinic\u2019s comments support CEQ\u2019s changes to the \u201cceiling\u201d provisions, which impermissibly limit agencies\u2019 discretion to provide additional procedures beyond the minimum standards identified by CEQ.<\/p>\n
Clinic students Elena Plenefisch, JD\u201923 and Samuel Yang, JD\u201922 prepared these comments under the supervision of Acting Director Shaun Goho, Senior Staff Attorney Aladdine Joroff, and Clinic Fellow Tommy Landers.<\/p>\n