New guidance requires closer look at climate impacts from activities on public lands

The U.S. is the second-largest producer of coal in the world, thanks in part to massive surface mines like this one in Wyoming. Photo courtesy BLM.
New guidance for federal agencies will require closer scrutiny of climate impacts of developments on public land. Photo courtesy BLM.

CEQ updates NEPA rules with an eye toward greenhouse gases

Staff Report

Public land managers and other federal agency decision-makers will no longer be able to shy away from considering climate change as they consider new projects.

Saying that emissions from any given proposal are only a small fraction of global emissions “is not an appropriate basis for deciding whether or to what extent to consider climate change impacts under NEPA,” the White House Council on Environmental Quality wrote in new guidance that directs agencies to quantify greenhouse gas emissions and to choose alternatives for projects that minimize climate impacts.

The guidance applies to the National Environmental Policy Act, a 1970 law sometimes referred to as the environmental Magna Carta. NEPA, as it’s know for short, requires all executive federal agencies analyze and disclose the environmental impacts of projects, and, when possible, to choose an alternative that’s least harmful to the environment. It also provides a framework for robust public participation in those evaluations.

The new guidance acknowledges the nature of the climate challenge: “the fact that diverse individual sources of emissions each make a relatively small addition to global atmospheric GHG concentrations that collectively have a large impact … Agencies should not limit themselves to calculating a proposed action’s emissions as a percentage of sector, nationwide, or global emissions in deciding whether or to what extent to consider climate change impacts under NEPA.

In press statement, the Natural Resources Defense Council hailed the new guidance as a “game-changer” in ongoing efforts to address climate impacts.

“Now federal agencies must fully and properly analyze the climate impacts of their proposed actions before deciding on how to proceed,” said NRDC president Rhea Suh. “They shouldn’t approve mines that will destroy the climate, or bridges that will get washed away. Climate change is the central environmental challenge of our time, and these guidelines can pave the way for smart policies that better protect our children, our health and our communities from dangerous carbon pollution and climate catastrophe.”

The guidance makes it clear that there are common and widely accepted tools that can be used to quantify emissions on various scales, from local to global.

Agencies should not only consider the direct, but also the indirect and cumulative impacts. In the case of a new coal mine, that could mean taking into consideration the emissions that will result from the combustion of the coal. In the case, for example, of a ski area expansion, U.S. Forest Service officials might have to consider the additional emissions that will result from additional chairlift operations and even from the additional traffic generated by skiers traveling to the resort.

This is how CEQ described the new guidance in a fact sheet. In addition to providing agencies with a reasoned approach as to how to describe climate change impacts, the guidance:

  • Advises agencies to quantify projected greenhouse gas emissions of proposed federal actions whenever the necessary tools, methodologies, and data inputs are available;
  • Encourages agencies to draw on their experience and expertise to determine the appropriate level (broad, programmatic or project- or site-specific) and the extent of quantitative or qualitative analysis required to comply with NEPA;
  • Counsels agencies to consider alternatives that would make the action and affected communities more resilient to the effects of a changing climate; and
  • Reminds agencies to use existing information and science when assessing proposed actions.


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