How Have Federal Agencies Implemented the CEQ Guidance on Climate Change and Environmental Reviews?

The Sabin Center has just published a new survey examining how federal agencies have been implementing the Council on Environmental Quality (CEQ)’s guidance on climate change and National Environmental Policy Act (NEPA) reviews. The survey, which was conducted by a team of Columbia undergraduate students as their capstone project for the Sustainable Development program, reviews 31 environmental impact statements (EISs) published in the fall of 2016 and explains how these EISs implemented specific aspects of the CEQ guidance. You can download the written report and accompanying excel database here:

  • Report: How Did Federal Environmental Impact Statements Address Climate Change in 2016? by Saloni Jain, Omri Klagsbald, Giovanna Leigh Crozier-Fitzgerald, Taylor Quinn and Elana Sulakshana
  • Excel Database: Detailed overview of climate change considerations in federal EISs, Sept. 2016 – Nov. 2016

The CEQ Guidance, published in August 2016, directs agencies to account for both the effects of federal proposals on climate change (through greenhouse gas emissions) and the effects of climate change on those proposals when conducting NEPA reviews, and contains detailed instructions on how to go about analyzing both issues. For this survey, the student team translated the guidance into a detailed rubric of climate change considerations and then used that rubric to evaluate whether each EIS was prepared in a manner that was consistent with the guidance.

Key findings from the survey included:

Emissions: Most of the EISs for proposals involving GHG-generating activities contained quantitative projections of those emissions. This was true even for proposals that were projected to generate relatively small quantities of GHGs. There were only 4 EISs that involved GHG-generating activities but did not quantify or qualitatively discuss the GHG contribution of those activities.

There was considerably more variation in the consideration of indirect emissions. While 16 of the EISs surveyed did contain some discussion of indirect emissions, the types of emission that were considered (e.g. emissions from induced vehicle trips and energy consumption) varied widely and there was no discernible explanation for the variation. Rather, it appeared that the indirect emissions analysis tended to occur on an ad hoc basis, perhaps due to a lack of guidance about the scope of indirect emissions that should be considered for different types of projects.

Finally, there was a noticeable absence of lifecycle emissions from fossil fuel EISs. Only addressed upstream emissions and only two addressed downstream emissions, which parallels the results from a previous survey of EISs prepared from 2012 through 2014.

Mitigation: Of the 20 EISs that identified GHG emissions, only 8 discussed mitigation measures. Where mitigation was not discussed, this decision was often justified on the basis that the overall GHG footprint of the action would be relatively small. None of the EISs that outlined mitigation measures included a mitigation monitoring plan to ensure that those measures were implemented and that they achieved the desired results. Overall, it appeared that GHG mitigation was not a priority for agencies.

Social Cost of GHG Emissions: Only 1 EIS used the federal social cost of carbon (SCC) to disclose the economic implications of the GHG emissions that would be generated as a result of the proposed action. This same EIS, which was prepared by the Bureau of Reclamation for the Navajo Generating Station-Kayenta Mine Complex Project (consisting of a coal mine and connected coal power plant), also contained the most thorough assessment of lifecycle emissions for a fossil fuel project.

Climate Change Impacts and Adaptation: Though most EISs (81%) discussed the impacts of climate change, only a few considered what implications these impacts might have for the environmental consequences of the proposal or whether measures were needed to make the proposal more resilient to the effects of climate change. Thus, agencies are recognizing that climate change will affect the local environment of the project, yet they are not proposing possible measures to adapt the project to account for those changes. In many cases, it appeared that the discussion of climate change impacts had very little bearing on decision-making about how to design and implement the proposed action. This is also consistent with findings from the previous EIS survey.

The Sabin Center has been conducting surveys of climate change considerations in EISs since 2009. All of our surveys are available on our website.