EPN Comments on Draft NEPA Analysis and Documentation Guidance for Greenhouse Gas Emissions

On June 26, 2019, the Council on Environmental Quality (CEQ) requested comments on its draft guidance to assist federal agencies in considering greenhouse gas (GHG) emissions when they evaluate federal actions under the National Environmental Policy Act (NEPA). Signed in 1970, NEPA requires federal agencies to assess the environmental impacts of their proposed actions before making decisions on such matters as permit applications, federal land management, and the commitment of federal funds for construction of highways and other publicly-owned facilities. 

Incredibly, the phrase “climate change” has been completely removed from the proposed guidance, and there is no recognition that not only do infrastructure projects and the built environment contribute to climate change, they must also be planned and constructed for resiliency to withstand its impacts. In response, EPN produced comments urging CEQ to reinstate the previous guidelines until a substitute that allows federal agencies to meet their responsibilities under NEPA and to the American people can be developed.