Discussion of Draft CEQ Guidelines for Addressing

Climate Change in NEPA Projects

Tim Stroope, NEPA Coordinator, GMUG National Forest

timothylstroope@fs.fed.usMarch 12, 2015

Outline

• 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

• 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 - Sequestration of carbon into long-lived products