“INGAA appreciates CEQ’s draft guidance clarifying the analysis required by agencies to evaluate greenhouse gas emissions (GHGs) for proposed energy infrastructure projects under the National Environmental Policy Act (NEPA). We agree that NEPA analyses need to be guided not only by the regulations, but also a rule of reason.
“As CEQ has acknowledged, agencies are not required under NEPA to engage in a cost-benefit analysis of the proposed action. Further, Social Cost of Carbon estimates were created for rulemaking purposes and are not appropriate tools to use in the context of an individual project-specific NEPA analysis.
“We agree that reasonably foreseeable emissions should only be quantified if it is practicable to do so using available data and tools. For example, it makes sense to use existing GHG inventory information to provide context regarding the relative magnitude of the GHG emissions from the proposed action. Agencies should utilize readily available information, rather than expending additional time and resources to conduct new research or analyses.
“INGAA looks forward to the opportunity to provide comments on the draft guidance. If finalized, CEQ’s guidance would ultimately help streamline the energy infrastructure permitting process – expanding Americans’ access to reliable, clean-burning, affordable energy while continuing to ensure that new and expanded infrastructure is safe and environmentally responsible.”
