Public Interest Comment on the Council on Environmental Quality’s Advance Notice of Proposed Rulemaking Update to the Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act

Abstract

This comment makes recommendations for how the Council on Environmental Quality (CEQ) could improve its data collection methods, how to use those data to enhance retrospective review of National Environmental Policy Act (NEPA) regulations, and how to align its procedural provisions for implementing NEPA with regulatory best practices such as benefit-cost analysis. The George Washington University Regulatory Studies Center improves regulatory policy through research, education, and outreach. As part of its mission, the Center conducts careful and independent analyses to assess rulemaking proposals from the perspective of the public interest. This comment on CEQ's Advance Notice of Proposed Rulemaking (ANPRM) for updating the regulations for implementing the procedures of NEPA does not represent the views of any particular affected party or special interest, but is designed to evaluate the effect of CEQ’s proposal on overall consumer welfare. This comment reflects the views of the author and does not represent an official position of the GW Regulatory Studies Center or the George Washington University.