August 21, 2018
IRLI makes the case to CEQ for a long-overdue analysis
WASHINGTON —The Immigration Reform Law Institute (IRLI) filed a public comment yesterday with the Council on Environmental Quality (CEQ) urging the council to amend its regulations. Specifically, IRLI urged CEQ to clarify that the several federal agencies involved in the regulation of immigration must conduct a National Environmental Policy Act (NEPA) analysis to determine the environmental impact of their population-increasing immigration-related actions.
In its comment, IRLI argues that federal immigration-regulating agencies—in particular, the U.S. Department of Homeland Security (DHS)—have ignored NEPA, our nation’s preeminent environmental law, for decades. Since it became law nearly half century ago, NEPA has required any agency, before implementing actions or programs that will affect the environment, to issue an Environmental Impact Statement analyzing and publicizing those effects. The federal government’s immigration programs are probably the most environmentally consequential programs there are, yet no such analysis has ever been done.
As such, IRLI recommended that CEQ clarify in its regulations that immigration-driven population growth poses an environmental impact subject to NEPA for which DHS and other immigration-regulating federal agencies must conduct an environmental assessment. “To continue to refuse to hold immigration-regulating agencies accountable to NEPA’s requirements not only violates NEPA,” IRLI argues “but completely undermines Congress’ goals and policies in enacting it.”
“By ignoring the effects that unchecked mass immigration has on our environment, federal agencies have wrongfully ignored NEPA for decades,” said Dale L. Wilcox, IRLI’s executive director and general counsel. “It is time for CEQ to stop turning a blind-eye to the government’s refusal to apply NEPA procedures to population growth inducing immigration programs that harm the environment. After all, if CEQ won’t stand up for the environment, who will?”
For additional information, contact: Brian Lonergan • 202-232-5590 • firstname.lastname@example.org
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