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| From | Shepherd, Gloria (FHWA) |
|---|---|
| Sent | Thursday, August 04, 2016 916 AM |
| To | FHWA Field Offices |
| Subject | INFORMATION CEQ’s Guidance on Climate Change in NEPA |
The purpose of this message is to make you aware of the Council on Environmental Quality’s (CEQ’s) just released guidance on Climate Change in NEPA and address initial questions regarding its implementation. On August 2, 2016, the CEQ issued Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews, which describes how agencies should address climate change in NEPA reviews.
The CEQ guidance applies to Environmental Assessments (EAs) and Environmental Impact Statements (EISs) and calls for an analysis of direct and indirect greenhouse gas (GHG) emissions from proposed Federal agency actions. The guidance establishes that the level of analysis should be commensurate with the quantity of projected GHG emissions. It also calls for consideration of the impacts of a changing climate on the proposed action and on the affected environment.
FHWA encourages a Planning and Environmental Linkages (PEL) approach. A planning level analysis could be a statewide level greenhouse gas analysis or an analysis at the MPO, corridor, or subarea planning levels. It would include an estimate of the difference in cumulative GHG emissions over the life of a transportation plan or study with or without implementing the transportation plan or project. Where a proposed project was included in a greenhouse gas analysis conducted at a planning level, the planning-level analysis may be incorporated by reference into the NEPA study (see FAST Act section 1305 and 23 U.S.C. 168).
Resources for conducting a PEL approach are available in the Environmental Review Toolkit at https://www.environment.fhwa.dot.gov/integ/index.asp and on the PlanWorks website at https://fhwaapps.fhwa.dot.gov/planworks/.
When a planning-level greenhouse gas analysis is not available or is not relevant for incorporation by reference into EAs or EISs, agencies should include a project-level greenhouse gas analysis. There are different methods for estimating such emissions and further information will be forthcoming.
The CEQ guidance calls for an assessment of the impacts of climate change on the proposed Federal agency action and on the affected environment when the project is located in an area considered vulnerable to the effects of climate change. FHWA Division offices should work with their State DOTs and MPOs to use the results of planning-level climate change vulnerability assessments and adaptation plans. These studies may include relevant and useful information that could be used in this analysis and can be incorporated into the NEPA study using a PEL approach.
The guidance applies to new proposed Federal agency actions where an EA or an EIS commences on or after the release date of the CEQ guidance, August 2, 2016. For EISs and EAs where environmental effects analysis is not substantially complete, agencies should include a climate change analysis where practicable. The guidance does not apply retroactively to completed EISs and EAs.
Our offices plan to provide additional information and technical assistance on approaches to GHG emissions analysis and incorporating climate change effects into NEPA studies. If you have any questions in the interim, please contact James Gavin in the Office of Project Development and Environmental Review (james.gavin@dot.gov), or Becky Lupes in the Office of Natural Environment (rebecca.lupes@dot.gov).
