Comment submitted by JCarpenter Law Office

Docket ID: EPA-HQ-OA-2025-1080Regulatory Information Number (RIN): 2020-AA53 Title: Update of Procedures for Implementing the National Environmental Policy Act and Assessing the Environmental Impacts of EPA ActionsTo Whom It May Concern, I am writing to express my strong opposition to the Environmental Protection Agency’s (EPA) proposed updates to its National Environmental Policy Act (NEPA) procedures, published under Docket ID EPA-HQ-OA-2025-1080. While efficiency in governance is important, the proposed changes compromise the core purpose of NEPA: ensuring thorough scientific scrutiny and robust public participation before major federal actions are taken. I am deeply concerned about this proposal for the following reasons: Weakened Environmental Oversight: Restricting reviews to only "reasonably foreseeable" consequences narrows the scope of analysis too far. This change will allow agencies to ignore complex, cumulative environmental degradation and long-term climate impacts. Furthermore, expanding categorical exclusions risks rubber-stamping projects that require deeper scrutiny. Compromised Review Quality: Imposing strict, arbitrary page and time limits on environmental reviews prioritizes speed over scientific integrity. Cutting corners to meet artificial deadlines will lead to incomplete data regarding local wildlife, water safety, and public health risks. Marginalization of Frontline Communities: Shortening review windows directly harms the public's ability to participate in the democratic process. This is a severe environmental justice concern. Low-income and minority communities—who frequently live closest to industrial sites—often lack the immediate resources to analyze complex technical data on a rushed timeline, effectively silencing their voices. Increased Legal and Economic Instability: Rushed, low-quality environmental reviews will inevitably result in flawed project approvals. This will trigger a surge in litigation from impacted communities and advocacy groups, ultimately causing worse project delays and regulatory confusion. For these reasons, I urge the EPA to withdraw this proposal and maintain rigorous, comprehensive NEPA review procedures that protect our environment and guarantee public input. Thank you for your time and consideration of these comments. Sincerely, JAMIE CARPENTER ST. GEORGE CITY UTAH JCARPENTER LAW OFFICELS PLLC ENVIRONMENTAL ATTORNEY