Position on NEPA Climate Guidance

NPCA strongly supports the issuance of the Council on Environmental Quality’s (CEQ) “Final Guidance on the Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in NEPA Reviews.” We also urge Congress to respect and protect the climate guidance so that all federal agencies can improve consistency and efficiency in the fight to protect our families, communities, and infrastructure from the devastating impacts of climate change.

This guidance provides much needed clarity to federal agencies’ existing responsibility to examine the impact of federal projects on climate change as well as the impact that climate change will have on our national infrastructure. It can also help inform climate adaptation efforts to ensure that the federal government is pursuing restoration projects that will endure in the face of sea-level rise. The rhetoric in our political climate does not change reality: the climate is changing. Consequently, our decisions—how we build our highways, bridges, energy sources, etc.—must adapt so that our infrastructure remains resilient, keeping lives safe and taxpayer dollars well-invested. Far from stopping energy and infrastructure development, this guidance gives the country secure footing towards better-informed projects that, in turn, secure our communities’ safety and our national energy independence.

The National Environmental Policy Act (NEPA) is one of our bedrock statutes that simply and sensibly requires the federal government to study and disclose the environmental impacts of federal projects and provides the public an opportunity to have a voice in those projects. It has long been settled that the assessment and disclosure of climate impacts falls squarely within NEPA. This guidance rightly affirms that climate change is a core consideration in the environmental review process and provides agencies with the much-needed tools to assess and analyze both positive and negative climate impacts effectively and consistently. This is an important step given the significant effects of climate change anticipated this century.

The rapid warming of the climate means the Federal government can no longer plan infrastructure, manage our natural resources, or protect our communities based on conditions of the past. Federal projects and decisions have an enormous impact on climate. With over 20 percent of all energy-related greenhouse gas emissions coming from federal lands and waters, it is critical that the Federal agencies analyze climate impacts with the best available science and disclose those findings so the public can weigh in on decisions that will irreversibly affect the health and safety of our communities. Critically, the consistent consideration of climate change outlined in this guidance will help ensure responsible investment of taxpayer dollars and the development of critical infrastructure projects that are resilient and responsive to the threats of climate change.

We strongly support this new guidance and hope that it is adopted across all agencies without delay. By consistently incorporating climate impacts into NEPA reviews, Federal agencies, communities, and decision makers will be informed about the very real, expensive, and irreversible impacts of climate change.