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Summary of National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions

Updated: Mar 27, 2023

In January 2023, the Council on Environmental Quality (CEQ) issued a draft rule on the National Environmental Policy Act (NEPA) titled, "National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change." This rule provides guidance for federal agencies to better understand and evaluate the potential environmental impacts of their actions. In this blog post, we will provide a comprehensive overview of the draft rule and its implications for federal agencies and the environment.

Context and Purpose

NEPA, enacted in 1970, is a cornerstone of the United States' environmental policy framework. It requires federal agencies to assess the environmental consequences of proposed actions before making decisions. As climate change continues to pose a growing threat to our environment, it is crucial to incorporate the assessment of greenhouse gas (GHG) emissions and climate change effects into the decision-making process. This draft rule aims to address these concerns by providing guidance on how to consider GHG emissions and climate change in NEPA reviews.

Key Provisions of the Draft Rule

  1. Direct and indirect GHG emissions: The draft rule directs federal agencies to consider both direct and indirect GHG emissions. Direct emissions are those produced by the proposed action itself, while indirect emissions result from the broader consequences of the action (e.g., emissions from increased energy consumption).

  2. Quantitative and qualitative analysis: The draft rule emphasizes the importance of quantifying GHG emissions whenever possible. However, it acknowledges that not all emissions can be quantified accurately. In such cases, agencies should provide a qualitative analysis to describe the potential effects on climate change.

  3. Assessing significance: The draft rule provides guidance on determining the significance of GHG emissions and their impact on climate change. It advises agencies to consider both the context and the intensity of the emissions when making this determination. Factors to consider include the project's magnitude, duration, and geographic scope, as well as its potential to contribute to cumulative GHG emissions.

  4. Consideration of alternatives: The draft rule encourages agencies to consider a range of alternatives that would minimize GHG emissions and climate change impacts. It also emphasizes the importance of analyzing the no-action alternative to help decision-makers understand the potential consequences of not taking action.

  5. Mitigation measures: If an agency determines that a proposed action would result in significant GHG emissions or climate change impacts, the draft rule directs the agency to consider appropriate mitigation measures. These measures may include reducing emissions, increasing energy efficiency, or sequestering carbon dioxide.

  6. Climate change adaptation and resilience: The draft rule highlights the importance of considering climate change adaptation and resilience in NEPA reviews. Agencies should assess the proposed action's potential to exacerbate climate change-related vulnerabilities and identify opportunities to enhance the resilience of communities and ecosystems.


The draft rule for the National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change is a critical step towards incorporating climate change considerations into federal decision-making. By providing clear guidance on assessing GHG emissions and climate change impacts, the rule will help ensure that federal agencies are better equipped to make informed decisions that protect our environment and promote sustainable development.


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