Full Disclosure: White House Addresses Climate Change With The National Environmental Policy Act

Written by Sarah Collins, intern with the Energy Opportunity team at the Center for American Progress and a graduate of the University of Michigan Gerald R. Ford School of Public Policy, and Brad Johnson.

Thursday, the Obama administration took an initial step to require all federal agencies to consider global warming impacts in their actions. This year is the fortieth anniversary of the enactment of the National Environmental Policy Act (NEPA), which requires federal agencies to prepare environmental impact statements for proposed projects. Among three new draft guidance documents issued yesterday by the White House Council on Environmental Quality (CEQ) with regard to the implementation of the NEPA was “Consideration of the Effects of Climate Change and Greenhouse Gas Emissions” (GHG). The draft guidance is two-fold:

MITIGATION: Agencies should “evaluate proposed mitigation of GHG emissions,” particularly for projects that would be responsible for “25,000 metric tons of direct CO2-equivalent GHG emissions.”

ADAPTATION: Agencies should take into account how “climate change impacts” could affect the project — for example, “climate change can affect the integrity of a development or structure by exposing it to a greater risk of floods, storm surges, or higher temperatures.”

The administration action follows the recommendations made two years ago by the Center for American Progress and other organizations. On May 5, 2008, the Center released “An Executive Order to Require Consideration of Global Warming Under the National Environmental Policy Act,” proposing measures released today in the guidance documents. Recommendations in the report outlined an Executive Order for NEPA that would provide an essential foundation for public information, increase understanding of the costs and consequences of federal actions, encourage federal actions that reduce greenhouse gas emissions, and promote investments that help adapt to the effects of global warming. The Center’s report was prepared by Christopher Pyke of the National Center for Ecological Analysis and Synthesis, and CAP environmental policy director Kit Batten, now Science Advisor in the Office of the Deputy Secretary of the Department of the Interior.


The Center’s recommendation followed up on concerns outlined in a February 28, 2008 petition of the International Center for Technology Assessment, Natural Resources Defense Council, and Sierra Club with the Council on Environmental Quality regarding the need for inclusion of global warming analyses in federal review documents.

Notably, however, the White House “does not propose to make this guidance applicable to Federal land and resource management actions.” This is a glaring omission, with respect to both climate change effects (for example, on wetlands and floodplains) and global warming emissions (for example, if the Energy and Interior departments coordinated on financing, planning, and permitting a series of projects on federal lands such as solar installations, wind farms, or oil and gas development).

This action is part of a comprehensive effort by the Obama administration for the executive branch to take climate change into account after eight years of inaction, above and beyond the Environmental Protection Agency’s regulatory steps and the State Department’s international diplomacy. These include new policies and considerations by the Department of Defense, the the Securities and Exchange Commission, and government-wide emissions-reduction plans.