This past December, the newest proposed draft of climate change guidance was issued by the Council on Environmental Quality to assess the effects of emissions created by development projects under the National Environmental Protection Act (NEPA). Confused? So are 99% of the American people. Luckily, SCI Foundation has taken up the immense task of understanding just what this would mean and the possible implications if it were adopted.
NEPA requires federal agencies to integrate environmental values into their decision making process by considering the impact their proposed actions will have on the environment. For example, before considering the construction of a new energy plant, federal agencies must look at how the plant will impact the environment. Agencies must meet NEPA requirements by compiling a detailed statement on the potential effects in a report called an Environmental Impacts Statement (EIS).
The proposed climate change guidance provides agencies direction on when and how to consider the effects of greenhouse gas (GHG) emissions and climate change in their evaluations and assist them in the creation of an EIS. The guidance would have agencies consider two additional questions: 1) What are the potential effects a proposed action has on climate change as indicated by its GHG emissions; and 2) What are the implications of climate change for the environmental effects of a proposed action?
If adopted, federal agencies would have to estimate the GHG emissions caused by their actions and the possibility of those actions increasing the effects of climate change. The agencies would also have to analyze how the already existing effects of climate change might affect their project. For example, a new power plant on the coast would have to consider how their emissions output might affect the surrounding environment, and they also would have to consider how projections of sea level rise may influence their location and building plans. To make it even more complicated, negative short term effects of a project may lead to positive long-term effects.
According to various sources, the guidance encourages the coordination of federal NEPA reviews with state, local, and tribal environmental review processes and with reviews under other federal laws such as the Endangered Species Act. This means that the proposed guidance could influence the information used to list species under the Endangered Species Act.
This new guidance raises issue with the NEPA process. Some find that such detailed guidelines are overly bureaucratic and unnecessary, while others feel the guidance does not impose strict enough requirements.
Those who petition for less stringent guidance say the cost of obtaining the necessary information is exorbitant and the means to obtain that information are often unknown. The agency must then rely on theoretical approaches, or summarize the existing relevant scientific research. Both of which are time consuming and may be misguiding for the project being considered.
Still, NEPA practitioners believe that less stringent guidance not only fails to highlight the importance of recognizing the impacts of climate change, but also places a void in the foundation of environmental accountability that NEPA established.
So who is right? Do we need increased government involvement to ensure the environmental health of our nation? Or do we trust agencies to effectively mitigate a project’s potential effects without being forced to hurdle the red tape of bureaucracy? Overall, this guidance is designed to provide better and more informed federal decisions regarding the effects of climate change and encourage agencies to remain consistent with existing NEPA policies. Abiding by these rules could potentially improve the quality of decision making in regards to expansion and development, but they could also stifle needed conservation and management actions. It is up to the agencies to understand the short and long term effects, think objectively about those effects and adjust procedures accordingly.
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