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Discussion of Draft CEQ
Guidelines for Addressing
Climate Change in NEPA Projects
Tim Stroope, NEPA Coordinator,
GMUG National Forest
[email protected]
March 12, 2015
Outline
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Overview of Forest Service guidance (2009)
Overview of DRAFT CEQ guidance (2014-15)
Comparison of FS and CEQ guidance
SBEADMR analysis and climate change
guidance
Forest Service Guidance
• Two types of climate change effects:
– Effect of proposed project on climate change
• GHG emissions and carbon cycling
– Effect of change on proposed project
• Changes in rainfall and temperature on seed stock
selection for reforestation after timber harvest
Forest Service Guidance
• Climate change considerations
– Do proposals meet the Agency’s mission while
also enhancing the resilience or adaptive capacity
of resources?
– Do elements of the proposal result in direct,
indirect or cumulative effects on GHG emissions
or carbon cycle?
• Direction of effects
• Temporal considerations
Forest Service Guidance
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Direct & Indirect Effects Analysis
GHG emission = direct effect
↑ global concentration = indirect effect
Quantify effects
– GHGs emitted and/or sequestered
– Not necessary, may help choose between
alternatives
– GHGs mix with global pool, not currently possible
to determine indirect effects of emissions from
single or multiple sources (projects)
Forest Service Guidance
• Quantitative effects continued
– Not possible to quantify actual climate change
effects based on project(s)
– Consider no action effect
• Qualitative effects
– Forests play major role in carbon cycle
– Nature and direction of processes
Forest Service Guidance
• Cumulative Effects
• Where appropriate:
– Quantify expected annual and total emissions
– Provide context for these numbers
– Qualitatively describe effects of GHG emissions on
climate change
CEQ Guidance
• Agencies should consider:
– Potential effects of proposed action on climate
change as indicated by its GHG emissions
– Implications of climate change for the
environmental effects of proposed action
• Apply routine and fundamental NEPA
principles and practices to the analysis of GHG
emissions and climate change
CEQ Guidance
• Direct, indirect and cumulative impacts
analysis of proposed action’s reasonably
foreseeable emissions and effects
• Consideration of reasonable alternatives and
short and long-term effects and benefits
analysis and mitigation to lower emissions
• Use a reference point to determine when GHG
emissions warrant quantitative analysis
– Use appropriate tools and data
CEQ Guidance
• Select appropriate level of action for NEPA review at
which to assess the effects of GHG emissions and
climate change
– Reasoned explanation for approach
• Use info developed during NEPA review to consider
alternatives that are more resilient to the effects of
changing climate
• Use existing info and tools when assessing future
proposed actions and provide some existing sources
of scientific info
CEQ Guidance
• Use projected GHG emissions and also, when
appropriate, potential changes in carbon
sequestration and storage as proxy for
assessing proposed actions
• If above reference point and not qualitative
analysis explain why
Guidance Comparison
• Very similar with respect to initial considerations and effects
analysis
• CEQ adds:
– Mitigation to lower emissions
– Using a reference point for quantitative disclosure
• 25,000 metric tons of CO2-e on annual basis
– Rationale for level of assessment of GHG and climate
change
– Consider alternatives that are more resilient to the effects
of climate change
– Use existing info, tools and science when assessing future
proposed actions
SBEADMRS
• CEQ guidance emphasizes the need to
consider GHG emissions and climate change
regardless of scale
– No additional weight given to climate change
analysis
• Effects will be disclosed in both quantitative
analysis and qualitative analysis
SBEADMRS
• Quantitative examples
– Emissions from burning slash
– Sequestration in forest products
– Vehicle emissions
• Qualitative examples
– Loss of labile soil carbon
– Changes in stable soil carbon
– General effects of increased emissions on climate
change
Conclusions
• Draft CEQ guidance compliments FS guidance
already in place
• A combination of qualitative and quantitative
effects analyses will inform the decision maker
• The climate change analysis in the draft EIS is
malleable and will likely change with input
received during the comment period
• Will update analyses as policy evolves or
changes
Activity
GHG Contribution
to Atmosphere
Rationale
Vehicles/Machinery
+
Combustion of fossil fuels
Road Construction
+
Combustion of fossil fuels
Slash Burning
+
Combustion of plant material
Salvage Logging
+
Loss of labile soil carbon
Decomposition
+/-
Carbon to atmosphere/Carbon to soil
Forest Products
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Sequestration of carbon into long-lived
products