NEPA and Climate Change: Things Are Starting to Heat Up

With the issue of climate change growing in importance both nationally and globally, we were curious how the topic is being treated in NEPA environmental impact statements. The U.S. EPA does not currently have standards or regulations for greenhouse gases like CO2, but draft guidelines have been issued.

EIS that we looked at to see if they mentioned climate changeTo get a sample, we looked at all of the transportation documents approved in July of 2010. The EISs comprise a variety of projects—airport improvements, roadways, waterway dredging, and rail projects (one transit and one freight).

We asked the following questions:

  • How often do the terms “climate change” and “greenhouse” (gases) appear in the main text of each EIS document? (We excluded tables of contents, page headings, references, and appendices.)
  • Which studies mention climate change and GHGs frequently, or not at all? Why might this be?
  • Where do climate change discussions occur in NEPA EISs?
  • What kinds of data sources are used in climate change/GHG discussions?
  • Do these projects yield positive or negative impacts, with respect to GHGs and climate change?

Here’s what we found:
Number of times Climate Change was mentioned in the NEPA EISFive out of eight studies mention climate change explicitly. All of these also mention GHGs, and another project mentions GHGs while omitting climate change (Grand Forks Air Force Base).

Two studies, the Missouri River Commercial Dredging DEIS in Missouri and the Circ-Williston Transportation Project FEIS in Vermont, make frequent mention of climate change (56 and 17 times, respectively).

Why so much in these two? As with most reports that include climate change, the Missouri River EIS acknowledges that GHGs are a “topic of increasing concern.” It also notes the adverse effects that are predicted for the region, and for the dredging industry, in a climate change scenario. The Circ-Williston EIS explicitly notes that GHGs were not considered in the Draft EIS, but public comments during the DEIS review prompted an analysis of daily energy consumption and GHG emissions for the county.

Where do discussions of climate change occur in these EISs?

Where do discussions of climate change occur in these NEPA EISs?Nearly all of these EISs include climate change in the Air Quality section of the “Environmental Consequences” chapter, and two of these also discuss it in the “Affected Environment” chapter section on air quality. The Circ-Williston EIS has different chapter headings than most NEPA analyses, but they devote an entire chapter to “Energy and Greenhouse Gas Emissions.” Only one project discusses climate change in the “Cumulative Impacts” chapter – the Missouri River EIS, which discusses climate change throughout the document.

What about those EISs that don’t mention climate change? Why not?
The projects that don’t mention climate change are the Pascagoula Harbor Navigation Channel Project in Mississippi, the R.J. Corman Railroad/Pennsylvania Lines Project in Pennsylvania, and the Grand Forks Air Force Base Project in Mississippi. It is most likely that they omit the climate change discussion because they are not currently required to include it by law. However, the details are interesting too:

In the case of the Mississippi harbor project, it appears that it is left out because this document is a Final Supplemental to an EIS that was approved in 1985—the project is extra construction that had been approved but never finished, and a recent federal bill provided funding for these unfinished projects post-Katrina.

In the Pennsylvania railroad project, no reason is given for leaving out an analysis of climate change or GHGs. However, the report does note that the proposed rail project would keep over 1,000 trucks per day off of the roads, and thus would be a better option with respect to air quality.

The Grand Forks EIS contains a ½-page discussion of greenhouse gases, but doesn’t mention climate change. The report describes GHGs as chemical compounds that trap heat, primarily resulting from fossil fuels, and compares the relative share of military and commercial aircraft in emissions (12 and 72 percent, respectively).

What kinds of data sources are used in climate change/GHG discussions?
It seems that in this group of EISes, there was little repetition in the kinds of data sources cited. Along with well-used climate change resources like the EPA’s National Ambient Air Quality Standards and Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse Gas Emissions, these were the primary resources used:

  • FHWA/Federal Transit Administration Policy Memorandum: Air Quality Conformity (gives guidance on air quality conformity requirements)
  • SIAC/Science Applications International Corporation, 2007 study, Public Transportation’s Contribution to U.S. Greenhouse Gas Reduction
  • Transportation Research Board’s Guidebook on Preparing Airport Greenhouse Gas Emissions Inventories
  • U.S. EPA and IPCC/Intergovernmental Panel on Climate Change’s estimates of project-level GHG emissions
  • IPCC / Intergovernmental Panel on Climate Change’s report on aviation’s effects on the global atmosphere
  • Vermont Department of Environmental Conservation’s 2007 report Final Vermont Greenhouse Gas Inventory and Reference Case Projections, 1990-2030.
  • 2006 Chittenden County Regional Plan

Do these projects yield positive or negative impacts on climate change?
This sample was a mixed bag, but positive overall. Of the four projects containing a climate change analysis, it was predicted that:

  • 2 would yield neutral impacts or no likely increase (TF Green, airport; Missouri River, waterway)
  • 1 would have positive impacts (Draper Transit Corridor, rail) and
  • 1 would have negative impacts (Circ-Williston, roads)

The I-69 Evansville to Indianapolis EIS is not included because it only mentioned, and did not analyze climate change or greenhouse gases. It is interesting to note that the Circ-Williston study in Vermont—the study with perhaps the most thorough analysis of climate change—is the only project expected to have a negative impact on greenhouse gas emissions. Not much can be drawn from this one example, though. If we were to study more EISes over time, there might be other interesting patterns.
Are there other useful resources that should be used in NEPA climate change analyses, that is not mentioned here? What are some other similarities and differences, between EISes that consider climate change and those that don’t?

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One Response to NEPA and Climate Change: Things Are Starting to Heat Up

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