Administrative Processes
Public decisions and planning processes often require extensive involvement by interested parties and the expertise to decipher mountains of technical information. CSE’s environmental law, economics, and environmental policy fellows help organizations be effective in administrative processes that are often exceedingly complex. We prepare administrative level comments and appeals on both a programmatic and site specific basis, and help organizations develop systems to monitor upcoming projects.
Some recent examples of our administrative process support work include:
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CSE and Redefining Progress Oppose Unsustainable Aquaculture in the Gulf of Mexico
CSE and its partner Redefining Progress submitted comments in opposition of a major expansion of unsustainable aquaculture operations in the Gulf of Mexico. The federal government and states are now considering opening up the entire Exclusive Economic Zone (EEZ) to aquaculture, or fish farming. The Gulf of Mexico and California are among the first regions targeted. Last fall, the Gulf of Mexico Fishery Management Council and the National Marine Fisheries Service issued a Draft Programmatic Environmental Impact Statement (DPEIS). While there are many types of low-impact aquaculture operations, the operations contemplated by the DPEIS include high trophic level carnivorous species that consume many times their weight in feed taken from wild fish stocks, pose additional risks to wild stocks through genetic contamination and disease, generate significant water pollution, and adversely affect a wide range of ecosystem services provided by healthy marine habitats. Read:
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Economic and Community Benefits of Protecting New Mexico's Inventoried Roadless Areas
CSE estimates that New Mexico's inventoried roadless areas on national forest lands generate tens of millions of dollars in economic benefits each year in the form of carbon sequestration, water filtration, backcountry recreation, game and non-game wildlife habitat, and scenery. We also found that counties with significant concentrations of roadless areas outperformed counties without by an average of 1.28% across four key economic performance measures. The study was prepared in support of Governor Bill Richardson’s successful petition to the Department of Agriculture for protection of roadless lands throughout New Mexico. Prepared for Forest Guardians, Santa Fe. Read:
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American Bird Conservancy and Forest Conservation Council vs. Federal Communications Commission, Docket # 05-1112, D.C. District Court of Appeals
The Federal Communications Commission (FCC) has decided to proceed with a proposed rulemaking to protect migratory birds. This victory comes in response to petitions and lawsuits filed by CSE (formerly Forest Conservation Council), American Bird Conservancy, and Friends of the Earth. Around 50,000,000 birds are killed by communication towers in the U.S. each year. If passed, the FCC rulemaking will mandate measures be taken by tower owners proven to help prevent these bird deaths at nearly 90,000 towers. The notice of this proposed rulemaking was issued on November 7, 2006 and has yet to be finalized. Read:
