The announcement of new guidance from the White House Council on Environmental Quality requiring agencies to consider climate change as part of their National Environmental Policy Act (NEPA) reviews caused a stir in the climate community. However, the implications can be challenging to convey to individuals less involved with the ins and outs of federal policy.
We asked a select group of climate leaders – Oil Change International’s David Turnbull, Sierra Club’s Liz Perera, and Earthjustice’s Raul Garcia – to reflect on the new guidance, the key takeaways to communicate, and opportunities for public engagement. Here’s what they told us:
DAVID TURNBULL
Campaigns Director, Oil Change International
Put simply: We need our energy policy to be aligned with our climate goals. This guidance takes an important step towards making that a reality. Science shows us that we must keep fossil fuels in the ground in order to avoid catastrophic climate change and yet our current energy policy in the United States would see the status quo of fossil fuel development continue. This new guidance rightfully encourages government agencies to consider the full lifecycle emissions associated with projects, and to make decisions based on whether those findings fit within what’s necessary to achieve our climate goals.
As we’ve seen with the Keystone XL pipeline and many other projects, when the public gets involved to highlight the risks these projects place on our communities and climate, decision-makers take notice. Fossil fuel infrastructure is no longer inevitable; in fact, most projects face stiff opposition. This guidance gives an important tool for those concerned with achieving our climate goals to ensure the government is adequately taking these issues into account. It specifically suggests that energy decisions should be aligned with climate policy, and the public can play an important role in ensuring that is the case.
Given how urgent the need is to reduce our emissions dramatically and keep fossil fuels in the ground in order to avoid catastrophic climate change, it’s essential that we consider the potential carbon consequences of every energy decision we make in this country. This guidance gives the direction needed to help decision-makers do that, and to relate the carbon consequences to the goals we’ve set to limit global warming. That’s an essential test that should guide approval or denial of any project.
While the guidance is an important development, more can be done to ensure our energy and climate policies are aligned. We at Oil Change International in partnership with a variety of organizations have developed the Climate Test, which lays out a rigorous test that energy projects should pass if they are to be approved. The NEPA guidance is an important step towards such a robust test, but a more comprehensive and binding approach is needed to ensure the best decisions are made in order to safeguard our climate. More on my views on the NEPA guidance are here.
LIZ PERERA
Climate Policy Director, Sierra Club
Climate disruption is a massive problem that requires us to make better decisions on every new project that we take on. The new guidance makes clear that agencies cannot avoid addressing climate change merely by claiming that a proposed project represents only a small fraction of overall carbon pollution. Next to an industry as a whole – or to state, national, or global emission levels – most projects look small by comparison, but that’s the nature of the challenge we face. Lots of small sources of pollution that collectively have a huge impact. The guidance makes clear that agencies cannot satisfy their obligation to evaluate and disclose climate impacts just because a project looks small compared to total emissions levels.
The guidance does a good job of providing agencies with the information and resources they need to give the public and decisionmakers meaningful information on climate impacts. In some places, however, the guidance seems to allow agencies wide discretion over which tools to use. For example, the social cost of carbon and social cost of methane are the best tools we have to evaluate not just the amount of greenhouse gas emissions, but the impact those emissions have on the environment. The guidance rightly notes that these can be useful tools in distinguishing between the climate impacts of alternatives, but it was an opportunity missed to clarify that these tools are available, have been used many times by federal agencies already, and should be used on an ongoing basis moving forward.
The key is giving communities and decision-makers the tools and information to make smarter decisions – particularly on climate disruption, which is the most pressing environmental issue we face. The guidance makes clear that agencies must lay out the climate impacts of each alternative in a clear, comparative format so that the public can understand the climate differences between approving a project and selecting the “no action” alternative, which in many instances would mean leaving fossil fuels where they belong: in the ground. Particularly when it comes to opening up public lands and waters for fossil fuel development, once communities, agency staff, and decisionmakers have clear options in front of them – backed by the best scientific tools we have available to help quantify greenhouse gas emissions – they can make smarter choices about how we get our energy.
This guidance does not create any new obligations. NEPA and its implementing regulations already require federal agencies to evaluate the climate impacts of the projects they approve and to disclose those impacts to the public. This guidance should help bring greater consistency to climate evaluations across federal agencies. Any cries that the sky is falling because there is new guidance to help agencies improve the analysis they’re already doing is pure applesauce.
RAUL GARCIA
Legislative Counsel, Earthjustice
This guidance empowers our communities to be better informed about the impacts of federal projects on climate change (and vice versa) and to participate in important decisions about the very real, expensive and irreversible impacts of climate change as they affect our health, safety, and way of life. Under the authority of the National Environmental Policy Act (NEPA), the guidance establishes a consistent and efficient way for agencies to consider and address climate change, the fundamental environmental impact of our time, when government projects could significantly impact our communities.
The guidance will keep the public better informed and consequently empower it with further influence over projects impacting and impacted by climate change. It creates consistency and predictability, encouraging the use of existing mechanisms to measure the impacts of our projects on climate change and the impacts of climate change on our projects. This consistency will make it easier for the public to read and understand these impacts and be more informed about how to identify problems, alternatives, and mitigation practices in projects that will contribute to climate change or that would be harmed by climate change. A better and more consistently informed public will, in turn, be more ready to influence and improve project decisions by offering local expertise addressing climate impacts.
Quantifying greenhouse gas (GHG) emissions is a way to measure the way projects contribute to a complex issue like climate change. It gives the public a base comparison from project to project and from region to region of the country to see how the benefits and burdens of a project are being distributed among communities. Climate change is an issue that affects us all but not necessarily in equal ways. By quantifying GHG emissions, we can become more aware of how we are sharing the benefits and burdens of our projects as they relate to climate change which can lead us to identify a more environmentally just way to balance benefits and detriments so that historically underrepresented communities are not stuck with all our the burdens while others enjoy all the benefits.
This guidance is a common sense document that uses already existing legal authorities to create consistency across the federal government. It ensures climate change is considered in NEPA analysis but it also tells agencies how to do it properly. The guidance is not unprecedented or unexpected in that its mandates simply follow what numerous courts and experts across the country have already said: the impacts of federal projects on climate change and the impacts of climate change on projects should be considered and addressed under the statutory authority granted by NEPA.
