Letter to CEQ Regarding NEPA Guidance on Consideration of Greenhouse Gas Emissions

The letter states that “CEQ’s draft ‘NEPA Guidance on Consideration of Greenhouse Gas Emissions,’ published in the Federal Register on June 26, 2019, fails to meet the challenges that our nation and the world face in regards to the climate crisis and associated environmental effects of Greenhouse Gas (GHG) emissions. It does not acknowledge that climate change is relevant to virtually all federal decisions, whether or not those decisions cause greenhouse gas emissions, because of the hotter and drier conditions, rising sea levels, ocean acidification, declining mountain snowpack, disappearing Arctic sea ice, and an unraveling of ecological systems. It fails to inform agencies of the latest scientific analyses regarding climate change and relevant judicial decisions. It fails to offer practical guidance about methodology, scope of analysis, and upstream and downstream effects. It fails to identify the clear requirement to consider alternatives that would lessen climate change and GHG emissions impacts and to identify and analyze reasonable mitigation measures. It omits any discussion of agency consideration of resilience and adaptation measures that might be integrated into an agency’s proposal or considered through alternatives analysis. It fails to address particular issues associated with land and resource management actions, such as how to approach the analysis of biogenic sources of carbon. It omits any discussion of the need for special attention to the impacts of climate change and GHG emissions, including health impacts, on vulnerable populations. It fails to do more than allude to the possibility of programmatic analyses and tiering. It fails to address the issue of incomplete and unavailable information. It even fails to offer much information about the NEPA process itself. Devoid of substance, the draft guidance fails to even acknowledge or use the phrase 'climate change’ entirely.”

Read the entire letter, which includes specific concerns and recommendations for improving the guidance in its final form.