This sounds like it could have an impact of USFS and BLM NEPA analyses for timber harvesting and other forest management projects. The new guidance is explained in the Federal Register. Legal firm Perkins Coie has an analysis here.
How NEPA guidance could favor climate projects over ecosystems
The White House interim greenhouse gas guidance could amplify climate considerations in a way that overshadows other environmental benefits, like preserving forests and wetlands.
The draft document, which directs agencies on how to treat climate change when reviewing projects under the National Environmental Policy Act, could show that things like solar arrays and transmission lines are more beneficial than protecting trees or marshes because of their potential for large-scale carbon reductions.
That’s because the guidance includes for the first time a monetary test to measure the costs and benefits of a project. And it’s weighted toward lowering emissions, due in part to the Biden administration’s soaring damage estimates from carbon dioxide.
The NEPA guidance, released earlier this month, stressed that agencies must consider indirect and cumulative greenhouse gas emissions associated with a proposed project, not only on-site emissions. Add that to an updated social cost metric, and the premium associated with avoiding greenhouse gases could be astronomical.
In contrast to the previous NEPA guidance on greenhouse gases finalized in 2016, it gives agencies very little wiggle room to claim that a project’s aggregate contribution to climate change can’t be estimated. In the “rare instance” that tools and methodologies aren’t available to allow a permitting agency to quantify all the direct, indirect and cumulative greenhouse gas consequences, the guidance states, the agency should offer a range of values instead.
Once the greenhouse gases are known, it states, monetizing them using the social cost figures should be a “simple and straightforward calculation.”
That prompts some experts to wonder whether this step toward cost-benefit analysis as a feature of NEPA review might cause other priorities like forest preservation, waterways or biodiversity to suffer by comparison — and perhaps to be sacrificed for projects that promise large climate gains.