Immigration and the environment

My comment relates to the Council on Environmental Quality’s (CEQ) Question 5 “Should CEQ’s NEPA regulations be revised to provide greater clarity to ensure NEPA documents better focus on significant issues that are relevant and useful to decision-makers and the public, and if so, how?”

CEQ’s National Environmental Policy Act (NEPA) regulations should be revised to clarify that agencies in charge of immigration policy may no longer ignore the environmental impacts of immigration. Currently, all of the agencies that implement immigration completely ignore the environmental impacts of immigration-induced population growth in their NEPA regulations. Immigration is responsible for almost all of our population growth today, and thus is the most environmentally significant issue that is relevant to decision makers and the public in 2018. NEPA was designed to give the public a voice on environmentally significant issues and NEPA ought to be used to give the public a voice on immigration.

The CEQ has long ignored the effects of immigration-driven population growth on the U.S. environment, despite the fact that NEPA specifically references the “profound influences of population growth” on the “natural environment.” NEPA regulations should be revised to reflect the language and intent of the law, and all agencies should be required to comply with NEPA’s requirements. Agencies that do not comply with NEPA regarding their actions on immigration policy need to explain this failure before Congress and to the American people.

The vast majority of U.S. population growth is attributable to immigration, with immigration projected to account for 88% of the U.S. population increase or 103 million people, to a still growing population of 441 million by the year 2065. The effects of this population growth on the U.S. environment is of such a magnitude that no reasonable interpretation of NEPA would exempt immigration policies from an environmental impact study. The intent of NEPA is to allow the public to hear and weigh the evidence of how public policy affects the U.S. environment. The CEQ has this opportunity to ensure NEPA is properly applied to immigration, and that the American people will be properly served by the law.

Greg Raven, Apple Valley, CA