EPA Narrows NEPA Analysis for Climate Impacts

EPA proposed amending its NEPA implementing procedures at 40 CFR Part 6, to narrow the scope of environmental effects that it must analyze when preparing an environmental impact statement (EIS) or environmental assessment (EA). EPA’s proposal would explicitly state that effects “should generally not be considered if they are remote in time, geographically remote, or the product of a lengthy causal chain,” relying on the Supreme Court's 2025 decision in Seven County Infrastructure Coalition v. Eagle County. Because climate change impacts from greenhouse gas emissions are diffuse, cumulative, and realized over medium- to long-range time horizons, this framing supplies EPA with a textual basis to exclude downstream and cumulative greenhouse gas effects (such as the climate impacts of a permitted facility's emissions over its operating lifetime, or upstream and downstream emissions connected to a federally funded project) from EIS and EA review.