The Council on Environmental Quality’s Proposal to Expand the Scope of NEPA Reviews to Include Climate Change Considerations Has 'Serious Deficiencies,' and Should Be Withdrawn Immediately, Industries Argue

摘要

The Council on Environmental Quality’s (CEQ’s) proposed policy spelled out in the Revised Draft Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews, released on 12/18/14, is “a far-reaching and costly” policy action “of untested legal basis,” according to comments from representatives of various industries including the energy sector. The draft “guidance” is proposing to set 25,000 tons per year of greenhouse gas emissions (GHG) as a threshold for NEPA benchmarking. But no scientific, reasoned or objective support is provided for this threshold, some parties argued. In addition, scientifically, it is “virtually impossible” to draw connections between a specific federal action and specific climate change effects, according to some of the opposing comments.