Tell the Biden Administration: You Have the Power to Fully Account for Climate

Right now, the Council on Environmental Quality (CEQ) is taking input on guidance that would help the administration choose a safer climate future. This guidance could arm federal agencies with a "climate test" that they could apply to major proposed energy projects, making it easier for them to choose climate-smart projects over fossil fuel infrastructure.

The only problem? CEQ's guidance isn't strong enough to meet the urgency of the climate crisis. Send a comment now to urge CEQ to include the strongest possible version of a climate test.

I’m honored to submit a comment in response to the interim National Environmental Policy Act (NEPA) Guidance on Consideration of Greenhouse Gas Emissions and Climate Change, under docket CEQ-2022-0005-0023.

As someone who cares deeply about the impacts of the climate crisis, I want to commend CEQ’s efforts to assist agencies in assessing the greenhouse gas emissions and climate effects of their proposed actions in support of larger emissions reductions. Thank you for endorsing the social cost of greenhouse gas (SC-GHG), recommending that federal agencies “apply the best available estimates of SC-GHG,” and recommending that agencies quantify “reasonably foreseeable emissions,” including direct, indirect, and cumulative emissions. Thank you, as well, for recommending that agencies explain how the proposed action and alternatives would help meet or detract from achieving relevant climate action goals and commitments.

These are important steps; however, the climate crisis demands a stronger and more urgent response. CEQ must go beyond these provisions to strengthen its interim guidance and meet that urgency.

CEQ’s interim guidance must:

1. Urge all federal agencies to conduct an objective, quantitative climate test on proposed new major energy infrastructure projects through NEPA. This climate test should assess the project’s GHG emissions and determine if a project is consistent with the necessary reductions in climate pollution we must achieve to avoid the worst impacts of climate change (including the science-based pathway of limiting global warming to 1.5°C).

2. When determining if a proposed fossil fuel action is compatible with a 1.5°C future, federal agencies must analyze the full lifecycle emissions of a project, including direct and indirect emissions. Federal agencies must not be permitted to factor in carbon offsets during this analysis. 

3. CEQ must strengthen its language on substitution analysis—specifically, substitution modeling cannot assume a fixed market demand for fossil fuels, and should not assume continued reliance on fossil fuels into the long-term future. 

Thank you for your attention to this comment and for your efforts to assist federal agencies in assessing the GHG emissions and climate change effects of their proposed actions and guide them toward decisions that protect our climate and our communities.

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