Council on Environmental Quality Issues Interim Guidance on Agency Consideration of GHG Emissions and Climate Change

On January 9, 2023, the Council on Environmental Quality (CEQ) issued interim guidance to assist agencies in analyzing greenhouse gas (GHG) and climate change effects of their proposed actions under the National Environmental Policy Act (NEPA). CEQ is issuing this guidance as interim guidance so that agencies may make use of it immediately while CEQ seeks public comment on the guidance. CEQ intends to either revise the guidance in response to public comments or finalize the interim guidance.

This guidance explains how agencies should apply NEPA principles and existing best practices to their climate change analyses by:

  • Recommending that agencies leverage early planning processes to integrate GHG emissions and climate change considerations into the identification of proposed actions, reasonable alternatives (as well as the no-action alternative), and potential mitigation and resilience measures;
  • Recommending that agencies quantify a proposed action's projected GHG emissions or reductions for the expected lifetime of the action, considering available data and GHG quantification tools that are suitable for the proposed action;
  • Recommending that agencies use projected GHG emissions associated with proposed actions and their reasonable alternatives to help assess potential climate change effects;
  • Recommending that agencies provide additional context for GHG emissions, including through the use of the best available social cost of GHG (SC-GHG) estimates, to translate climate impacts into the more accessible metric of dollars, allow decision makers and the public to make comparisons, help evaluate the significance of an action's climate change effects, and better understand the tradeoffs associated with an action and its alternatives;
  • Discussing methods to appropriately analyze reasonably foreseeable direct, indirect, and cumulative GHG emissions;
  • Guiding agencies in considering reasonable alternatives and mitigation measures, as well as addressing short- and long-term climate change effects;
  • Advising agencies to use the best available information and science when assessing the potential future state of the affected environment in NEPA analyses and providing up to date examples of existing sources of scientific information;
  • Recommending agencies use the information developed during the NEPA review to consider reasonable alternatives that would make the actions and affected communities more resilient to the effects of a changing climate.

On February 16, 2023, CEQ extended the period for comment in response to public requests for an extension of the response period. CEQ will accept comments on the interim guidance until April 10, 2023.