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The White House Council on Environmental Quality (“CEQ”) has released draft guidance that would direct federal agencies to consider climate change when evaluating proposed federal actions under the National Environmental Policy Act (“NEPA”). The guidance does not establish any clear requirements, but it does advise agencies to consider the greenhouse gas emissions of the proposed action, as well as the effects climate change might have on the underlying project. Under CEQ’s approach, agencies should generally consider a quantitative assessment of both direct and indirect emissions if a proposed action would be reasonably anticipated to cause direct annual emissions of 25,000 metric tons or more of carbon dioxide equivalent. CEQ is careful not to characterize this threshold as determinative of significance under NEPA; instead it presents it as a reference point to help guide agencies in their analysis. It also notes that long term actions with emissions below that threshold may still warrant quantitative study. The guidance does not apply to land and resources management actions – which would include oil and gas drilling on federal lands – but CEQ has solicited comments on how to assess the climate change effects of these activities.
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