Addressing Greenhouse Gases and Climate Change in NEPA Reviews As A Regulatory Agency

The contemporary issues of greenhouse gas (GHG) emissions and climate change impacts have been receiving widespread attention over the last decade. For Federal agencies implementing the National Environmental Policy Act (NEPA), these issues have caused consternation because there has been very little guidance as to how to address these issues within NEPA analyses. In the last few years, training courses have been established to assist agencies in addressing their GHG footprints and climate change impacts. However, there has been little opportunity for Federal agencies to learn from each other about this topic due to different regulatory authorities and the recent emergent nature of this issue in the NEPA landscape. Over the last few years, U.S. Nuclear Regulatory Commission (NRC) staff has worked to address the dual issues of accounting for GHG impacts from a proposed project and the impact of climate change on resources affected by the proposed project. This paper will discuss successes and difficulties encountered by the NRC staff when trying to address these topics in NEPA reviews, what has been gleaned from training courses, Council on Environmental Quality (CEQ) guidance, review of other Federal agency Environmental Impact Statements (EIS), and finally, the frameworks developed specifically to address these topics for new reactor construction and operational emissions.