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Tuesday, March 16, 2010

Climate Change & NEPA

The U.S. White House has taken steps toward the development of climate change guidance for the National Environmental Policy Act (NEPA), one of the key environmental policy instruments for minimising adverse environmental consequences from federally-funded projects. The Council on Environmental Quality has published a draft guidance document for comment, the overall intention of which can be summarised as follows:

"With regards to the effects of climate change on the design of a proposed action and alternatives, Federal agencies must ensure the scientific and professional integrity of their assessment of the ways in which climate change is affecting or could affect environmental effects of the proposed action. Under this proposed guidance, agencies should use the scoping process to set reasonable spatial and temporal boundaries for this assessment and focus on aspects of climate change that may lead to changes in the impacts, sustainability, vulnerability and design of the proposed action and alternative courses of action. At the same time, agencies should recognize the scientific limits of their ability to accurately predict climate change effects, especially of a short-term nature, and not devote effort to analyzing wholly speculative effects. Agencies can use the NEPA process to reduce vulnerability to climate change impacts, adapt to changes in our environment, and mitigate the impacts of Federal agency actions that are exacerbated by climate change."


While a White House source is quoted as saying the guidance is "straightforward, common sense," the release no doubt prompted many rumblings throughout Washington, if not the nation. While the utility of mainstreaming consideration for climate change into agency actions appears initially to be self-evident, the challenge of making such consideration routine is significant. As of yet, there are no standard methods for the assessment of climate change impacts, vulnerability or risk and, similarly, the evaluation of adaptation options and their costs remains a young and naive practice. Meanwhile, the challenges associated with carbon accounting are perhaps even more profound. Should such guidance go forward to become part of the NEPA process, we are sure to see the rapid expansion of practitioners in climate assessment and carbon management. At some point, however, someone should give thought as to how those practitioners will be trained and what methods and standards they will employ.

UPDATE (5/4/2010): Congressional Republicans (led by James Inhofe) are apparently not particularly pleased with the proposed incorporation of climate change into NEPA.

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