On the recordOctober 22, 2015
I would urge rejection of this amendment because it would make the permitting process for critical and strategic minerals even worse than it currently is. It is already 7 to 10 or more years. It is dead last in the 25 major mineral-producing countries in the world, according to that recent study we cited earlier. This amendment would strike several key sections of the bill, including the NEPA provisions, the expedited schedule provision, the time limit provision, and the applicability of this law to existing permit application provision. First, this amendment seeks to remove the NEPA provisions. Our provision does not sidestep or avoid the NEPA process in any way; rather, it codifies a judicial determination for NEPA known as the functional equivalence doctrine. This doctrine provides that, when an agency action, whether State or Federal, has addressed the substantive requirements of NEPA, such action may be substituted as sufficient rather than having to prepare an entirely new and duplicative environmental study. This amendment rejects the functional equivalence doctrine and mandates that the issuance of every mineral exploration or mine permit constitutes a ``major Federal action,'' thereby requiring the development of costly and time-consuming environmental impact statements, regardless of a proposed project's size.…





