March 10, 2020

Submitted via Regulations.gov and via email to [email protected]

Mary B. Neumayr Chair Council on Environmental Quality 730 Jackson Place NW Washington, DC 20503

Re: Docket No. CEQ-2019-0003, Notice of Proposed Rulemaking, Update to the Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act

Dear Ms. Neumayr:

On behalf of our millions of members and supporters across the country, the undersigned 331 conservation, health, and justice organizations and businesses urge the Council on Environmental Quality (CEQ) to withdraw the Notice of Proposed Rulemaking (NPRM) and retain the existing CEQ regulations that properly implement the National Environmental Policy Act (NEPA).1

The deeply flawed and illegal changes in the NPRM would silence public input and purge informed, science-based decision-making from the federal environmental review process. They would put industry, developer, and polluter interests before public health and safety, and before the health of our waters, lands, air and wildlife. The changes create significant risks for frontline and indigenous communities that are already disproportionately harmed by pollution, flooding, and climate change.

NEPA is a critical tool for saving lives and protecting the environment for the health, safety, and well- being of future generations. The existing CEQ regulations correctly implement NEPA’s action forcing procedures that include giving the public a voice in federal decisions that affect the environment, carefully reviewing the environmental impacts of proposed actions, and investigating less environmentally harmful alternative actions. Reviews carried out under the current regulations have exposed the true cost of environmentally damaging and ill-conceived proposals, leading to better solutions and substantial savings for federal taxpayers.2

For example, NEPA review led to an inter-agency agreement halting construction of a dangerous new levee, protecting vulnerable Mississippi River communities from flooding, preventing the loss of 50,000 acres of wetlands, and saving taxpayers more than $345 million. NEPA review of a Corps of Engineers’ proposal to dredge ’s Bolinas Lagoon showed that the project would cause extensive harm to one of the most pristine tidal lagoons in California and was not necessary. The misguided proposal was then abandoned, saving taxpayers $133 million, and the non-federal sponsor developed a community- supported plan to restore and manage the lagoon. NEPA review protected public health and the environment by allowing a coalition of tree planters, rural residents and scientists in the Pacific

1 Many of our organizations will also be submitting individual comments and/or joining other group comments urging CEQ to withdraw the NPRM. 2 While NEPA implementation has been far from perfect, the information and public involvement obtained through the NEPA process has provided enormous benefits to people, wildlife, and the environment across the country. Comments Opposing the NEPA NPRM March 10, 2020 Page 2

Northwest to work with the Forest Service to develop an effective, less-costly, and safer nonchemical weed control alternative in lieu of toxic herbicides.

The changes proposed in the NPRM would unravel the vital protections provided by NEPA, threatening the health, safety, and well-being of people and wildlife across the country. Among many other unacceptable and illegal changes, the NPRM would:

1. Eliminate NEPA review for many projects: The proposal attempts to exclude many projects from environmental review and public input under NEPA. Among other things, the NPRM creates new tests for determining whether NEPA applies at all to a project (including by changing the definition of “major federal action”) and allows agencies to exempt a project from NEPA review by determining that some other type of analysis would serve the same purpose. These changes could allow agencies to move forward with controversial projects – including building pipelines, roads, dams, floodgates, and levees – without any NEPA review or opportunity for public comment.

2. Ignore severe environmental, public safety, and health impacts: The proposal would severely limit the types of impacts examined during a NEPA review. The NPRM’s directive that analysis of cumulative effects “is not required” would eliminate review of a project’s role in increasing climate change and many other types of harm. It would also dispense with review of rising sea levels, stronger storms, and other climate change impacts on the effectiveness and resilience of a proposed project. Agencies could also ignore many types of severe impacts based on the NPRM’s elimination of all references to “indirect” effects, and its directive to review only impacts with a “reasonably close causal relationship” to the proposed action. These changes could let agencies ignore the long-term impacts of toxic pollution from gold or copper mines; the risks of new levees diverting floodwaters onto other communities; and loss of wetlands caused by reservoir management practices that starve a river of the water flows needed to sustain those wetlands.

3. Allow projects to be approved even if critical scientific and technical information is missing: The proposal would give agencies the green light to make decisions without scientific and technical information essential to making a reasoned choice among project alternatives. The NPRM specifically states that agencies “are not required to undertake new scientific and technical research to inform their analyses.” This could let agencies approve navigation infrastructure, major river dredging projects, reservoir operating plans, and large flood projects without conducting the research needed to understand the impacts of those projects on flooding, habitat loss, or ecosystem health.

4. Significantly weaken the review of alternatives: The proposal would significantly weaken the assessment of alternatives during a NEPA review, dramatically undermining NEPA’s fundamental purpose of exploring less environmentally harmful approaches to achieving the project purpose. The NPRM eliminates the requirements to “rigorously explore and objectively evaluate all reasonable alternatives” and to consider reasonable alternatives not within the jurisdiction of the lead agency. The NPRM instead directs a much less extensive review, requiring only that agencies “evaluate reasonable alternatives to the proposed action.”

Comments Opposing the NEPA NPRM March 10, 2020 Page 3

5. Allow agencies to ignore critical public input: The proposal creates loopholes that could let federal agencies ignore public comments, effectively silencing the communities and individuals that could be harmed most by a federal action. The NPRM would let agencies ignore public comments that they deem are not “specific” enough or do not include reference to data sources or scientific methodologies. The NPRM improperly places the burden on the public to list any and all possible impacts of a proposed project; to provide specific language changes; and to “explain why an issue raised is significant” to the consideration of impacts to the environment, the economy, employment and potential alternatives. Comments most likely to be ignored include those from the general public; those from frontline communities without resources to fund technical reviews; and those that rely on traditional knowledge rather than technical data. The NPRM also creates new hurdles to challenging a flawed environmental review in court.

6. Allow project applicants to write their own environmental reviews without conflict of interest safeguards: The proposal eliminates longstanding safeguards designed to protect the independence and integrity of environmental reviews. Under the current regulations, the federal agencies prepare NEPA reviews and agencies can only hire consultants to assist in a NEPA review after obtaining disclosures of any conflicts of interest or financial stakes in the project the contractor would be reviewing. The NPRM, however, lets companies prepare their own NEPA reviews – despite their clear interest in obtaining project approval. Agencies could also hire contractors without obtaining a conflicts of interest disclosure.

The changes proposed in the NPRM would wreak havoc on communities, wildlife, and the environment. We urge CEQ to withdraw the NPRM and retain the existing NEPA implementing regulations that have properly served the nation for more than 40 years.

Sincerely,

Bo Webb Don Riepe Campaign Director Director, NE Chapter ACHE American Littoral Society

Cindy E Lowry Katherine Robb Executive Director Senior Program Manager Alabama Rivers Alliance American Public Health Association

Maria De Luna Eileen Shader National Policy & Advocacy Coordinator Director, River Restoration Alianza Nacional de Campesinas American Rivers

Susan Inman Joseph Zupan Altamaha Coastkeeper Executive Director Altamaha Coastkeeper Amigos Bravos

Steve Holmer Thomas Anderson Vice President of Policy Administrative Director American Bird Conservancy Amigos De Bolsa Chica Comments Opposing the NEPA NPRM March 10, 2020 Page 4

Trey Sherard Kathy Phillips Interim Riverkeeper Assateague COASTKEEPER Anacostia Riverkeeper Assateague Coastal Trust

Olivia Anderson Dean A. Wilson Project Coordinator and Development Lead Executive Director Anacostia Riverkeeper Inc. Atchafalaya Basinkeeper

Marjorie Levine Heather Cantino Director Steering Committee Chair Angler Action Foundation Athens County's Future Action Network, a.k.a. Athens County (OH) Fracking Action Network Bethany Cotton Terrestrial Wildlife Director Scott Zucker Animal Welfare Institute Vice President Audubon Everglades Georgia Ackerman Riverkeeper & Executive Director Jill Mastrototaro Apalachicola Riverkeeper Policy Director Audubon Mississippi Mary Varson Cromer Deputy Director Dan VanNorman Appalachian Citizens' Law Center, Inc. President of Audubon Chapter and Alternate Delegate to the Everglades Coalition Joe Lovett Audubon of Southwest Florida Executive Director Appalachian Mountain Advocates Connie M. Ericson Advocacy Chair Brendan Mysliwiec Audubon Society Northern Virginia Director of Federal Policy and Legislation Appalachian Trail Conservancy Bob Sallinger Conservation Director Jim Vogt Audubon Society of Portland President Aquashicola/Pohopoco Watershed Kevin Graff Conservancy Vice-President Baltimore Bird Club Francisco Lopez President Kevin Emmerich Arrecifes Pro Ciudad Inc. Director Basin and Range Watch Constantino Aucca President of ECOAN Jordan Macha Asociacion Ecosistemas Andinos - ECOAN Executive Director & Waterkeeper Bayou City Waterkeeper

Comments Opposing the NEPA NPRM March 10, 2020 Page 5

Bob Fisher John Cassani Communications Chair Calusa Waterkeeper Bird Conservation Network Calusa Waterkeeper

Charles Scribner Lori Haus-Bulcock Executive Director Board of Directors Black Warrior Riverkeeper Cape Coral Friends of Wildlife

David C Perry Kemp Burdette Executive Director Cape Fear Riverkeeper Blue Ridge Land Conservancy and Central Cape Fear River Watch Virginia Land Conservancy Parker Agelasto Jenn Aiosa Executive Director Executive Director Capital Region Land Conservancy Blue Water Baltimore Glenn Wahl Rebecca Roter Co-Founder Chairperson Cattaraugus-Chautauqua for Clean Water Breathe Easy Susquehanna County David C. Kyler Beth K. Stewart Co-Director Executive Director Center for a Sustainable Coast Cahaba River Society Joe Laszlo Myra A Crawford Facilitator Executive Director Central Illinois Healthy Community Alliance Cahaba Riverkeeper Reed Perry Sean Bothwell Government Relations Specialist Executive Director Chesapeake Conservancy California Coastkeeper Alliance Judy Pollock Nick Jensen President Lead Conservation Scientist Chicago Audubon Society California Native Plant Society Michael William Mullen Bill Jennings Riverkeeper/Executive Director Executive Director Choctawhatchee Riverkeeper California Sportfishing Protection Alliance John Koeferl Linda Castro President Assistant Policy Director Citizens Against Widening the Industrial Canal California Wilderness Coalition Aimee Erickson Michael J. Painter Executive Director Coordinator Citizens Coal Council Californians for Western Wilderness Comments Opposing the NEPA NPRM March 10, 2020 Page 6

Natasha Leger Larry Baldwin Executive Director Waterkeeper Citizens for a Healthy Community Crystal Coast Waterkeeper

Anne Coglianese William Franks Coastal Resilience Program Manager President City of New Orleans Cumberland-Harpeth Audubon Society

Jennifer Peters Peg Furshong National Water Programs Director Director of Programs Clean Water Action CURE (Clean Up the River Environment)

Ken Dolsky Frank James Organizer Staff Director Coalition Against Pilgrim Pipeline - NJ Dakota Rural Action

Emily Vuxton John Murtaugh Policy Director Representative, Rockies and Plains Coalition to Restore Coastal Louisiana Defenders of Wildlife

Bayard Ewing Diane Rosencrance Chair, Conservation Committee Executive Director Colorado Native Plant Society Delaware Highlands Conservancy Brett VandenHuevel Matthew Sarver Executive Director Conservation Chair Columbia Riverkeeper Delaware Ornithological Society

Clark Bullard Maya K. van Rossum Director the Delaware Riverkeeper Committee on the Middle Fork Vermilion River Delaware Riverkeeper Network

Brigid Lawlor Anne Bekker U.S. Provinces Advocacy Liaison Conservation Co-Chair Congregation of Our Lady of the Good Delaware Valley Ornithological Club Shepherd, U.S. Provinces Angelo DePaola Heather A. Govern, Esq. Owner and operator Vice President and Director, Clean Air and Depe Oysters LLC Water Program Babak Tondre Conservation Law Foundation (CLF) President & Co-Owner Jesse Demonbreun-Chapman DIG Cooperative Inc. Executive Director & Riverkeeper Mary Gutierrez Coosa River Basin Initiative/Upper Coosa Director Riverkeeper Earth Ethics, Inc. Comments Opposing the NEPA NPRM March 10, 2020 Page 7

Amy Rosmarin Carol Hoover / Skye Steritz Executive Director Executive Director / Program Manager Earthkeeper Health Resources Eyak Preservation Council / Copper River Delta Sound Waterkeeper Aaron Mintzes Senior Policy Counsel Blair Schilling Earthworks Attorney Fishman Haygood, LLP Daneeta Loretta Jackson Producer Bill Tanger Elektrik Zoo Films, Inc. Vice President and Conservation Chair Float Fishermen of Virginia Dan Silver Executive Director Emma Haydocy Endangered Habitats League Director Florida Bay Forever Morgan Patton Executive Director Michael Chenoweth Environmental Action Committee of West President Marin Florida Division of the Izaak Walton League of America Maureen Cunningham Senior Director for Clean Water Mark Perry Environmental Advocates of New York Executive Director Florida Oceanographic Society Caitlin Hart Senior Legislative Analyst Liz Kirkwood Environmental Defense Fund Executive Director FLOW (For Love of Water) Thomas Wheeler Executive Director Dave Peterson Environmental Protection Information Center Conservation Chair Fly Fishers International Michelle Roos Executive Director Sherry Pease Environmental Protection Network Executive Director Foothill Conservancy Steve Box Executive Director Spring D Ligi Environmental Stewardship Nature Instructor Frederick Bird Club - MOS Jim La Rochelle President Judith Rodd Evanston North Shore Bird Club Director Friends of Blackwater, Inc.

Comments Opposing the NEPA NPRM March 10, 2020 Page 8

Ivy Frignoca Dawn Buehler Casco Baykeeper Kansas Riverkeeper & Executive Director Friends of Casco Bay Friends of the Kaw

Glenda Booth John C McCue President Chairman Friends of Dyke Marsh Friends of the Middle River

Andrew N Tyler Trevor A Russell Consultant Water Program Director Friends of Fakahatchee Friends of the Mississippi River

Kevin Chapdelaine Scott C Yaich President Board Member Friends of Pool 2 Friends of the North Fork and White Rivers

Scott Beauchamp Ronald Martin Stork Policy Director Policy Director Friends of the BWCA Friends of the River

Bob Clarke Bill Tanger President Chair Friends of the Central Sands Friends of the Rivers of Virginia Amanda Pitzer Kathleen J. Vasvary Executive Director Missionary Friends of the Cheat Friends of the Santa Cruz River

Jim Pfiffer Bob Stokes Executive Director President Friends of the Chemung River Watershed Galveston Bay Foundation

Kristin Larsen Yvonne Taylor Executive Director Vice President Friends of the Cloquet Valley State Forest Gas Free Seneca

Robert Burns Peter Duffey Detroit Riverkeeper Board Director Friends of the Detroit River George's River Land Trust

Marcie Keever Michael Worley Director, Oceans & Vessels Program President & CEO Friends of the Earth Georgia Wildlife Federation

Barbara Ullian Linda Stone Chair VP Admin & Gulf Coast Programs Friends of the Kalmiopsis Global Green Comments Opposing the NEPA NPRM March 10, 2020 Page 9

Rachael Thompson Theaux Le Gardeur Executive Director Gunpowder RIVERKEEPER Glynn Environmental Coalition Gunpowder RIVERKEEPER

Pam Young Captain Bill Sheehan Executive Director Riverkeeper & Executive Director Audubon Society Hackensack Riverkeeper

Rick Eichstaedt Emily Sutton Director/Attorney Haw Riverkeeper Gonzaga University Environmental Law and Haw River Assembly Land Use Clinic Sean Grace Fred Akers President Administrator Hawk Mountain Sanctuary Great Egg Harbor Watershed Association Cynthia Sarthou Shelley Silbert Executive Director Executive Director Healthy Gulf (formerly Gulf Restoration Great Old Broads for Wilderness Network)

Bruce A. Morrison April Peebler President Executive Director Great Rivers Environmental Law Center Heirs To Our Oceans

David Stokes Stephen Buczynski Executive Director President Great Rivers Habitat Alliance Hendry-Glades Audubon Society

Veronica Warnock Matt Reed Conservation Director Public Lands Director Greater Hells Canyon Council High Country Conservation Advocates

Fran Teplitz Patricia Adams Executive Co-director Attorney Green America Holy Cross Neighborhood Association

Sascha Bollag Indra Frank Attorney Director of Environmental Health and Water Green Justice Policy Hoosier Environmental Council Charlie Cray Business and Political Strategist Aaron Lehmer-Chang Greenpeace Co-owner House Kombucha

Comments Opposing the NEPA NPRM March 10, 2020 Page 10

Richard Webster Vicki Nichols Goldstein Legal Director Founder & Director Hudson Riverkeeper Inland Ocean Coalition

Jennifer Kalt Shiney Varghese Director Senior Policy Analyst Humboldt Baykeeper Institute for Agriculture and Trade Policy

Colleen McNally-Murphy Michael R. Schmidt Associate National Director Staff Attorney Hydropower Reform Coalition Iowa Environmental Council

Nic Nelson Joe Wilkinson Executive Director President Idaho Rivers United Iowa Wildlife Federation

Bonnie Duman Jared Mott Board Member Conservation Director Illinois Audubon Society Izaak Walton League of America

Edward L Michael Jim Scheff Government Affairs Chair Director Illinois Council of Trout Unlimited Kentucky Heartwood Tamima Itani Tom Fitzgerald Vice President and Treasurer Director Illinois Ornithological Society Kentucky Resources Council

Liz Stelk Pat Banks Executive Director Director Illinois Stewardship Alliance Kentucky Riverkeeper

Howdy Henritz Ward G. Wilson President Executive Director Indian Creek Watershed Association Kentucky Waterways Alliance

Michael Conner Kimberly Baker Executive Director Executive Director Indian Riverkeeper Klamath Forest Alliance

Emily A Wood Joseph Vaile Executive Director Climate Program Director Indiana Wildlife Federation Klamath-Siskiyou Wildlands Center

Megan Brousseau Patricia Schuba Associate Director President Inland Empire Waterkeeper Labadie Environmental Organization (LEO) Comments Opposing the NEPA NPRM March 10, 2020 Page 11

Lori Fisher Mary Ploeser Executive Director Co-Chair Lake Champlain Committee League of Women Voters Upper Mississippi River Region Inter League Organization Sandy Bihn (LMVURRILO) Executive Director Lake Erie Waterkeeper Sandy Rosenthal Founder and President Reinaldo Diaz Levees.org Waterkeeper Lake Worth Waterkeeper Angela Shugart Executive Director Rena Cohen Little River Waterkeeper President Lake-Cook Chapter, Illinois Audubon Society John Weisheit Conservation Director Cindy Brown Living Rivers & Colorado Riverkeeper Executive Director Land Trust for Louisiana Michael Myers Executive Director Deborah A Aldridge Loudoun Wildlife Conservancy President Last Stand Dr. Barry Kohl President Rebecca Jim Louisiana Audubon Council Tar Creekkeeper LEAD Agency, Inc. John A. Ruskey Founding Director Matthew Davis Lower Mississippi River Foundation Legislative Director League of Conservation Voters Ted Evgeniadis Lower Susquehanna Riverkeeper Nancy Porter Lower Susquehanna Riverkeeper Association Director League of Women Voters of Iowa Laura Paul Executive Director Cathy Eisenhofer lowernine.org President League of Women Voters of Johnson County Drew Martin Iowa Conservation Chair Loxahatchee Group Jessica Jones Capparell Legislative and Policy Affairs Senior Manager Karen Forget League of Women Voters of the United States Executive Director Lynnhaven River NOW

Comments Opposing the NEPA NPRM March 10, 2020 Page 12

Colin Rees Rachel Bartels Steering Committee Chair Director Maryland Bird Conservation Partnership Missouri Confluence Waterkeeper

Kurt R. Schwarz Dana Ripper Conservation Chair Director Maryland Ornithological Society Missouri River Bird Observatory

Jen Lomberk, Esq. Craig Sterle Matanzas Riverkeeper Division Past President Matanzas Riverkeeper MN Division-Izaak Walton League of America

Michael Collins Meredith Diskin President Program Coordinator Memphis Tennessee Ornithological Society Mobile Baykeeper

Rachel Silverstein Patrice Tomcik Executive Director & Waterkeeper Project Manager, State Campaigns Miami Waterkeeper Moms Clean Air Force

Sean Hammond Eric Harder Policy Director Youghiogheny Riverkeeper Michigan Environmental Council Mountain Watershed Association Ayako Nagano Gray Jernigan Managing Attorney Southern Regional Director and Green Midori Law Group, P.C. Riverkeeper MountainTrue David Schmitt Executive Director Darryl E Malek-Wiley Mill Creek Alliance CEO M-W & Associates Cheryl Nenn Riverkeeper Cynthia Routledge Milwaukee Riverkeeper President Nashville Chapter of Tennessee Ornithological Albert Ettinger Society Legal Counsel Mississippi River Collaborative Lawrence E. Couch Director Kelly McGinnis National Advocacy Center of of the Executive Director Good Shepherd Mississippi River Network Ani Kame'enui Heather Navarro Deputy Vice President, Government Affairs Executive Director National Parks Conservation Association Missouri Coalition for the Environment Comments Opposing the NEPA NPRM March 10, 2020 Page 13

Laura Daniel Davis William Rossiter Chief of Policy and Advocacy Vice President National Wildlife Federation NY4WHALES

Veronica Bowers Kathryn Heintz Director Executive Director Native Songbird Care & Conservation NYC Audubon

Diana and Byron Steskal Michael Stocker Nebraska Landowners Director Nebraska Easement Action Team (NEAT) Ocean Conservation Research

George Cunningham Courtney Vail Board Member Director of Strategic Campaigns Nebraska Wildlife Federation Oceanic Preservation Society

Elliott Ruga Damon Mullis Policy & Communications Director Executive Director/Riverkeeper New Jersey Highlands Coalition Ogeechee Riverkeeper

Susan Michelle Silber Rich Cogen Director Executive Director NorCal Resilience Network Ohio River Foundation Carrie Clark Jackie Antalan Executive Director Director of Outreach & Programs North Carolina League of Conservation Voters Operation HomeCare

Matt Norton Mark Salvo Policy Director Program Director Northeastern Minnesotans for Wilderness Oregon Natural Desert Association

Michael J. Goff Doug Heiken President and CEO Conservation and Restoration Coordinator Northeast-Midwest Institute Oregon Wild

Nina Bell J. Sam Miller Executive Director Organizer Northwest Environmental Advocates Our Water, Our Air, Our Rights

Jonah Sandford Vivian Stockman Staff Attorney Executive Director Northwest Environmental Defense Center OVEC-Ohio Valley Environmental Coalition

Gregory Remaud Brenda Curtis Baykeeper & CEO Board Member & Conservation Chair NY/NJ Baykeeper Peace River Audubon Comments Opposing the NEPA NPRM March 10, 2020 Page 14

Rev. Sandra L. Strauss Joe Siegrist Director of Advocacy and Ecumenical Outreach President/CEO Pennsylvania Council of Churches Purple Martin Conservation Association

Howard Penn John Ruskey Executive Director Owner, Founder Planning and Conservation League Quapaw Canoe Company

Pat Lupo, OSB and Sarah Peelman Tom Sobal Co-chairs Director PLEWA, Pennsylvania Lake Erie Watershed Quiet Use Coalition Association Phil Irwin Peter Hudiburg Vice President Founder Rappahannock League for Environmental Plymouth Friends for Clean Water Protection

Phillip Musegaas Bill Shultz Vice President of Programs and Litigation Raritan Riverkeeper Potomac Riverkeeper Network Raritan Riverkeeper

Marcia Westkott Eleanor Hines Chair North Sound Baykeeper Powder River Basin Resource Council RE Sources for Sustainable Communities

Nancy Hilding Marianne Cufone President Executive Director Prairie Hills Audubon Society of Western South Recirculating Farms Coalition Dakota Jen Pelz Ryan Grosso Rio Grande Waterkeeper Water Resources Associate Rio Grande Waterkeeper (WildEarth Prairie Rivers Network Guardians)

Roseanna Sacco Lisa Wittenborn President Program Director Preserve Monroe Rivanna Conservation Alliance

Lucia Bogatay Raj Shukla President Executive Director Presidio Historical Association River Alliance of Wisconsin

Alyssa Barton Katherine Baer Policy Manager Director of Science and Policy Puget Soundkeeper River Network Comments Opposing the NEPA NPRM March 10, 2020 Page 15

Barbara L. Walsh Tonya Bonitatibus Executive Director Riverkeeper Rockbridge Area Conservation Council (RACC) Savannah Riverkeeper/Waterkeeper

Roz McClellan Carol Campbell Coordinator Member Rocky Mountain Recreation Initiative Save EPA

Stacey Detwiler Joseph Bogaard Conservation Director Executive Director Rogue Riverkeeper Save Our Wild Salmon Coalition

Don McEnhill Kate McPherson Executive Director Narragansett Bay Riverkeeper Russian Riverkeeper

Trygve B. Sletteland Michael Rice Founder and Executive Director Director Council (subsumed into Save the Cape, Inc. Sacramento River Preservation Trust) Gary Wockner David Harrison Executive Director Conservation Director Save The Colorado Salem Audubon Society Kay Charter Diane Wilson Executive Director Executive Director Saving Birds Thru Habitat San Antonio Bay Estuarine Waterkeeper Joseph Campbell Sejal Choksi-Chugh President Executive Director Seneca Lake Guardian, A Waterkeeper Affiliate San Francisco Baykeeper Matt Pluta Christine Canaly Choptank Riverkeeper Director ShoreRivers San Luis Valley Ecosystem Council Dalal Aboulhosn Gail Musante Deputy Legislative Director official signer Sierra Club Sanford-Oquaga Area Concerned Citizens (S- Carol Adams-Davis OACC) Vice Chair Laura Early Sierra Club Mobile Bay Group Executive Director Sandra Seberger Satilla Riverkeeper Chairman Sierra Club-Black Hills Comments Opposing the NEPA NPRM March 10, 2020 Page 16

Charles Marsh Kathy Hawes President Executive Director Sleepy Creek Watershed Association Tennessee Clean Water Network

Snake River Waterkeeper David Whiteside Executive Director Executive Director Snake River Waterkeeper Tennessee Riverkeeper

Dave Willis Rhiannon Lewis-Stephenson Chair Communications and Development Coordinator Soda Mountain Wilderness Council The Environmental Protection Information Center (EPIC) Laura Sue Fuderer Conservation Chair Barbara Heskins Davis South Bend-Elkhart Audubon Society Vice President Programs The Land Conservancy of New Jersey Brad K. Evans Waterkeeper Mike Petersen South Platte River Waterkeeper Executive Director The Lands Council Bob Lukinic Conservation Chair Steve Shimek Southern Maryland Audubon Society Executive Director The Otter Project and Monterey Coastkeeper Sharon Yoker Secretary of TriLakes Fly Fishers Heather Smith Southwest Missouri Fly Fishers Grand Traverse Baykeeper The Watershed Grand Traverse Bay Lisa Rinaman Riverkeeper Ann Witsil St. Johns Riverkeeper Interim Executive Director The Wetlands Conservancy Suzannah Glidden Co-founder Paul Botts Stop the Algonquin Pipeline Expansion (SAPE) President & Executive Director The Wetlands Initiative Andre Mele Executive Director Drew McConville Suncoast Waterkeeper Sr. Managing Director, Government Relations The Wilderness Society Angela Howe Legal Director Richard McNutyt Surfrider Foundation President Tidewaters Gateway Partnership Inc. Justin Bloom Director Jennifer Mckay Tampa Bay Waterkeeper Policy Director Tip of the Mitt Watershed Council Comments Opposing the NEPA NPRM March 10, 2020 Page 17

Ashley Short Angie Rosser Riverkeeper & In-House Counsel Executive Director Tualatin Riverkeepers West Virginia Rivers Coalition

Sandra Schubert Troy Redding Executive Director Community Organizer Tuleyome Western Colorado Alliance

Lee First Barbara Vasquez Twin Harbors Waterkeeper Oil and Gas Chair Twin Harbors Waterkeeper Western Organization of Resource Councils

Richard M Frank Larry Baldwin Professor of Environmental Practice Advocacy Director U.C. Davis School of Law White Oak-New Riverkeeper Alliance

Andrew Rosenberg Jeremy Nichols Director, Center for Science and Democracy Climate and Energy Program Director Union of Concerned Scientists WildEarth Guardians

Guy Alsentzer Christine Ellis Executive Director Executive Director Upper Missouri Waterkeeper Winyah Rivers Alliance Mary Rafferty Julie E Wille Executive Director Co-founder of Women for Wild Lands Virginia Conservation Network Women for Wild Lands

Christina Hausman Rhode Edgar Miller Executive Director Executive Director Voyageurs National Park Association Yadkin Riverkeeper

David Groenfeldt, PhD Emma Reisinger Director Gardener, Organization President Water-Culture Institute Yellow House Farm

Betsy Nicholas Melinda Booth Executive Director Executive Director and Waterkeeper Waterkeepers Chesapeake Yuba River Waterkeeper

Jen Lomberk, Esq. Vice Chair, Waterkeepers Florida

Waterkeepers Florida

Rhiannon Tereari'i Chandler-'Iao Executive Director Waterkeepers Hawaiian Islands