White House Council on Environmental Quality releases revised draft guidance for greenhouse gas emissions and climate change impacts

The National Environmental Policy Act (NEPA) requires federal agencies to consider and disclose the potential effects of their actions and decisions on the environment. Recently, the White House Council on Environmental Quality (CEQ) released revised draft guidance that describes how federal departments and agencies should consider the effects of greenhouse gas (GHG) emissions and climate change in their NEPA reviews. The document supersedes draft GHG and climate change guidance released by CEQ in February 2010.

The revised guidance explains that agencies should consider both the potential effects of a proposed action on climate change, as indicated by its estimated GHG emissions, and the implications of climate change for the environmental effects of a proposed action. The guidance emphasizes that agency analyses should be commensurate with projected greenhouse gas emissions and climate impacts, and should employ appropriate quantitative or qualitative analytical methods. It recommends that agencies consider 25,000 metric tons of carbon dioxide equivalent emissions on an annual basis as a reference point below which a quantitative analysis of GHG emissions is not required unless it is easily accomplished using available tools and data. 

Unlike the 2010 draft guidance, the revised draft guidance applies to all proposed federal agency actions, including land and resource management actions. The draft guidance notes that “it is important to recognize that land management practices such as prescribed burning, timber stand improvements, fuel load reductions, scheduled harvesting, and grazing land management can result in both carbon emissions and carbon sequestration.” It recommends that NEPA analyses include “a comparison of net GHG emissions and carbon stock changes that would occur with and without implementation of the anticipated vegetation management practice.”

CEQ is soliciting public comment on this revised draft guidance for 60 days. More information about the draft guidance is available at http://www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/ghg-guidance.