What Happened
The Council on Environmental Quality (CEQ) published interim guidance on analyzing greenhouse gas (GHG) emissions and subsequent climate change impacts under the National Environmental Policy Act (NEPA) on January 9, 2023. This guidance updates CEQ’s 2016 interim guidance and clarifies that federal agencies should disclose project GHG emissions, including the social cost of those emissions. The guidance also recommends avoidance of GHG emissions through consideration of alternatives and/or mitigation of GHG impacts to the extent possible. Of particular importance is the guidance’s emphasis on quantifying impacts, including reasonably foreseeable indirect GHG emissions (i.e., cradle-to-grave carbon footprint). Additionally, the guidance indicates that less detailed analysis would be required for projects that result in net reductions in GHG emissions or that have very small GHG emissions, which is potentially good news for renewable energy projects. This guidance also has ramifications that expand the potential scope of the environmental justice analysis, particularly in light of Executive Order 13990, which specifically links climate change to environmental justice.
What to Watch
For the full text of the CEQ guidance, click on the link below. Although the new guidance is currently in effect, CEQ is accepting comments on it through March 10, 2023, with the…
