The Council on Environmental Quality (CEQ) released revised draft guidance on December 18, 2014 that describes how federal agencies should consider the effects of greenhouse gas (GHG) emissions and impacts of climate change when performing environmental reviews under the National Environmental Policy Act (NEPA). Unlike the 2010 draft guidance, the new version applies to all proposed federal agency actions, including land and resource management actions.

Specifically, the guidance urges federal agencies to consider two topics:

• “the potential effects of a proposed action on climate change as indicated by its GHG emissions; and
• the implications of climate change for the environmental effects of a proposed action”

The guidance seeks to provide federal agencies with a reasoned approach to analyzing the impacts of GHG emissions and on climate change in NEPA documents. Among other facets, the guidance proposes a reference point of 25,000 metric tons of CO₂ -equivalent emissions annually above which a quantitative analysis of greenhouse gas emissions is recommended. The guidance also recommends federal agencies to consider alternatives that would be more resilient to climate change and emphasizes the importance of analyzing the effects of GHG emissions and climate change at a level appropriate to the proposed project or action.

Comments on the draft revised guidance will be accepted until February 16, 2015.

Interested in learning more? Check out this article on how the new revised guidance could spur slower permitting at the Federal Energy Regulatory Commission (FERC).