The White House Council on Environmental Quality on 18th December released the second draft version of a guidance document on how federal agencies should consider climate impacts in preparing Environmental Impact Assessments under the National Environmental Policy Act. The first draft version was released in 2010. CEQ invited public comments for 60 days.
In keeping with NEPA regulations that require Environmental Impact Statements to consider the direct, indirect, and cumulative environmental impacts of proposed projects and actions, the guidance document recommends that the direct, indirect, and cumulative impacts of greenhouse gas emissions be included in preparing EISs. This includes “upstream” and “downstream” emissions connected to the project. Thus a new bridge that would allow the transport of tens of millions of tons of energy-intensive goods over its lifetime could have an enormous carbon footprint.
Reports stated that the guidance document recommends that climate impacts be considered in the NEPA process when any project or action would increase greenhouse gas emissions by at least 25,000 metric tons of carbon dioxide-equivalent annually.
This is not correct. The document states that a quantitative analysis is only necessary when emissions exceed 25,000 tons annually. Considering the impacts of lower annual emissions is required but does not necessarily require quantification.
The guidance does contain a caution on the use of the Social Cost of Carbon guidance document: “When using the federal social cost of carbon, the agency should disclose the fact that these estimates vary over time, are associated with different discount rates and risks, and are intended to be updated as scientific and economic understanding improves.” In other words, tomorrow’s Social Cost of Carbon estimate may be much lower than tomorrow’s. The document also notes that global general circulation models “may have limitations on how they can be used in regional or local impact studies.”
The guidance also cautions that providing a boilerplate paragraph that the emissions from a proposed action constitute “only a small fraction of global emissions is more a statement about the nature of the climate change challenge,” and “is not helpful to the decision maker or public” because that is true of every particular action.
Some news reports have suggested that the guidance will apply mainly to new fossil energy production on federal lands or offshore areas. This is also incorrect. The guidance applies to all matters that fall under NEPA regulation: “all federal proposed actions, including individual federal site-specific actions, federal grants for funding of small-scale or broad-scale activities, federal rulemaking actions, and federal land and resource management decisions. Federal rulemaking decisions includes Clean Water Act and other federal permits required to build new factories, bridges, highways, airports, and mines, as well as pipelines, coal terminals, offshore oil fields, etc.
Under the NEPA process, one of the alternatives must always be, “no action,” which means, don’t proceed with the project being studied. Once direct, indirect, and cumulative greenhouse gas emissions are included, it is likely that any big new project will be found to have environmental impacts so large that the “no action” alternative will be preferred by federal regulators.
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The guidance probably mentions that SCC may change over time because it already has. The original climate change induced damage estimates were quickly revised dramatically upward, by about 50%. The guidance is correct that SCC is very complex, not a single number. What the guidance does not say is that SCC is absurd, which it most certainly is. These are economic damage models going out 300 years or more. The truth is that there may be no damage at all, so using SCC is a very bad policy, one that needs to be stopped.
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