Considering Climate Change in NEPA Implementation

Abstract

Attention to anthropogenic aspects of global climate change has become widespread in the United States where concern for this and related issues such as greenhouse gas (GHG) emissions has increased through time from the 1990s to the present. This has been of increasing concern among federal agencies. A number of federal government undertakings have the potential to impact and be affected by this environmental aspect. The Council on Environmental Quality (CEQ) has highlighted a relationship between climate change and the National Environmental Policy Act (NEPA) by issuing draft guidance on how it may be considered under NEPA. This paper reviews how climate change has been considered in NEPA implementation in terms of CEQ guidance and a sample of environmental planning documents, along with important federal court decisions relating climate change to NEPA. It also provides information on recent federal executive branch and legislative activity concerning climate change and discusses the near future outlook for such action. I offer suggestions for how climate change may be addressed when preparing a NEPA categorical exclusion, environmental assessment, and environmental impact statement by considering climate change impacts separately from greenhouse gas emissions. While the principal climate change focus in the NEPA process has been GHG emissions and their relationship to global warming, it may be worthwhile to also consider natural variation.