NEPA GHG Guidance

The CEQ has released a new Draft Guidance on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change.The link goes to a press release with a link to the new document (which, unfortunately, is a static document that you can’t searched or copy-and-paste from).

CEQ press release excerpt:

As part of an ongoing effort to modernize implementation of the National Environmental Policy Act and promote effective and transparent environmental reviews, the Council on Environmental Quality (CEQ) today released updated draft guidance for Federal agencies on how to consider greenhouse gas emissions and the impacts of climate change in their NEPA analyses, as well as final guidance on conducting programmatic NEPA reviews. These measures will increase the efficiency of environmental reviews and help agencies make informed decisions that are sound investments of taxpayer dollars and good for American communities.

NEPA requires Federal agencies to consider and transparently disclose the potential effects of their actions and decisions on the environment.  In many cases, Federal actions have the potential to produce greenhouse gas emissions, and also are at risk of experiencing impacts from a changing climate. The draft guidance, which will be available for 60 days of public comment, outlines how Federal agencies should describe these potential effects when conducting NEPA reviews to allow decision makers and the public to more fully understand the environmental impacts of proposed actions.  In turn, agencies will be better able to compare alternatives, and consider measures to reduce the impacts of climate change on Federal resources and investments.

Excerpt from an E&E News article (subscription):

Steven Weissman, director of the University of California, Berkeley, School of Law’s energy program, said it appears the guidance gives federal agencies a large amount of discretion and contributes to the impression that some effects of greenhouse gas emissions are acceptable.

Weissman pointed to CEQ’s guidance for agencies to focus on projects and actions that will release more than 25,000 metric tons of CO2-equivalent emissions on an annual basis. CEQ said a “quantitative analysis of greenhouse gas emissions is not recommended unless it is easily accomplished” for projects that emit anything below that amount.

That means smaller projects that emit less — but still contribute to climate change — may not get a close look, he said.

“Basically, they’re saying you could level over 160 acres’ worth of trees before you reach any level of significance, or burn 20 million tons of coal,” he said. “It’s all very interesting because there’s no particular number that’s magical here; this is just an effort to set a benchmark [to prevent] too much attention on projects that would have smaller effects.”


  1. this seems kind of strange to me…

    “contributes to the impression that some effects of greenhouse gas emissions are acceptable.”

    So none are acceptable?It seems to me that we have a society in which people drive around in cars, heat their homes, use electricity to blog, eat food produced with electricity and trucked in using fossil fuel.. Or even sending bureaucrats overseas to the latest climate talks requires GHG’s.

    • Sharon, those examples aren’t effects, they are causes. There may be some effects that some people will find acceptable, e.g., we may start being able to reliably grow tomatoes in (a warmer) north Idaho. But there’s a strong scientific consensus that incremental GHG increases contribute to effects that overall are unacceptable. Many of the causes do have societal benefits, as you note.

      One point that Weissman addresses, that small GHG-emitting activities can get ignored via agency discretion, because “they don’t really count that much”, has a strong analogy that’s often seen in USFS approaches to endangered/threatened species: the idea that localized extinctions shouldn’t really matter all that much, because they don’t individually affect the species over its “entire range”. The 9th Circuit made a good observation that also may have an analogy in the GHG discussion: “This type of slow slide into oblivion is one of the very ills the ESA seeks to prevent.” 524 F.3d 917, 930 (9th Cir. 2008).

      • We have also seen where “protected” wildlife PACs have burned to a crisp, providing huge amounts of GHG’s, depriving species of essential nesting habitats and causing all sorts of other impacts that us humans don’t like. Indeed, those “protected” areas in the Rim and King Fires pushed those GHG’s far into the upper atmosphere, where carbon-sequestering plants cannot reach. Again, the ESA hasn’t been “protecting” those areas from drought, bark beetles and wildfires. However, it has been “protecting” them from thinning projects and salvage operations, designed to reduce the intensity and size of future wildfires.

      • Guy, I know the difference between an environmental cause and effect. Why are you analyzing effects if you don’t think the federal activities cause them? Seems like a waste of time. What am I missing about your argument?

        Yes, I agree that small changes can get ignored. Like a lot of driving around to do work. Or the impacts of making people work at home and heat individual home instead of heating a leased or federally owned building.

        When we look at GHG’s most of the things the FS does are, in fact, tiny. Why would governments analyze those instead of, say, the policy of legalizing marijuana in Colorado and Washington? In my mind it’s because we can force agencies to through the courts, and not because it’s the best use of government and people resources.

  2. Just can’t let this one go. I support the need for our scientists to disclose the impacts of their proposed management actions on the human environment, but I am concerned with depth of analysis that goes into this evaluation. I have observed the analysis process for numerous proposed actions and find the reports and documents provide a reasonable review of the scientific knowledge the scientist has learned through the education process and continued book study, but almost totally lacking in site specific knowledge of the land unit to be treated. Preparing these environmental documents requires so much time, the scientist has little if any time to “Read the Land”. Being able to predict the impacts and outcomes of proposed management actions requires having the time to observe the detail and complexity of the communities that have been identified for treatment. As we continue to overwhelm our biologists and scientists with paper work, the further we get away from observing and understanding the complexity of NATURE and the multitude of relationships that are active within each individual forest communities. In our efforts to improve our understanding, we are becoming more and more removed from being able to understand the human environment we depend upon for the sustenance of life! WHEN WILL WE WAKE UP?

    • Part of “reading the land” is fully comprehending the effect of land management on the planetary systems that sustain life. You can’t separate the local for the global. They are linked. Doing the paperwork is the only way we know that they have fully and accurately “read the land.”

      • Sadly, some people think they can “read the land” from their cushy offices in Missoula, Eugene, Washington DC and New York City. They want a blanket concept of “Whatever Happens” across the land, from coast to coast, without “doing the paperwork” of analyzing that hands-off policy, which includes converting forests to brushfields, and pushing those GHG’s into our atmosphere. Not to mention the fact that brushfields sequester a lot less carbon than healthy forests, on a longterm basis. Some people don’t want to address the idea of Land Use Changes from catastrophic wildfires. Instead, they myopically consider those firestorms to be “natural and beneficial”. That mindset surely does not come from a reasoned and objective analysis of all the issues. It’s a knee-jerk parroting that continues to fill the comments sections of failing publications.

        These ideas should be included in any and all applicable “No Action” alternatives.

  3. Taking a more pragmatic approach, it seems like any project that uses such “guidance” will be at-risk to unnecessary litigation loopholes. I’m sure that someone will say that this new “guidance” is actually designed to limit analysis and repel litigation, by simply changing the rules. It doesn’t sound like something I want to see attached to critical, time-sensitive projects.

  4. I should have noted that the draft guidance is open to public comment for 60 days. However, I have yet to find any info about how to submit comments. Nothing in the Federal Register, so far.

  5. If you use old, slow-growing, overstocked, drought-impacted forests to study the effects of increased CO2 on growth, it will yield just one answer. This is yet another example of designing a study to exclude some characteristics and effects to “prove” something that really isn’t true. If CO2 is the limiting factor, then yes, there will be accelerated growth in those forests. If water, nutrients, light and/or temperature is the limiting factor(s), the increase in growth due to increased CO2 will be minimal.

    Disclaimer: I am neutral on “climate change” issues.

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