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CEQNonrulemakingCEQ-2022-0005

National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change

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Natural Resources Defense Council (NRDC) filings
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Natural Resources Defense Council (NRDC) filed 1 comment on this docket between Apr 11, 2023 and Apr 11, 2023. 43 other organizations filed here. The comment window closed 1205d ago.

What Natural Resources Defense Council (NRDC) filed (1)

Apr 11, 2023· Comment from Natural Resources Defense Council· CEQ-2022-0005-0363

The Honorable Brenda Mallory Chair, Council on Environmental Quality 730 Jackson Place NW Washington, DC, 20503 Re:Request for comments on interim National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change (88 FR 1196, Docket ID: CEQ-2022-0005) Dear Chair Mallory: The Natural Resources Defense Council (NRDC) appreciates the opportunity to comment on the Council on Environmental Quality (CEQ)'s interim National Environmental Policy Act (NEPA) Guidance on Consideration of Greenhouse Gas (GHG) Emissions and Climate Change (hereinafter "Interim Guidance"). This Interim Guidance, on analyzing GHG emissions and climate change effects in agencies' NEPA implementation, is an important step forward in CEQ's direction on this most critical and cross-cutting issue. NRDC is a signatory to a more comprehensive set of comments submitted by a coalition of public interest organizations. Please see attached file to review NRDC's supplemental comments, focused on forthcoming carbon budget-based tools. The full comment is attached as file name "2023.04.10_NRDC supplemental comment on CEQ-2022-0005_fin.pdf". It is submitted along with Attachment 1, containing a draft manuscript in review describing the tool. Due to the forthcoming nature of the attached work, we would prefer, and so request, that CEQ opt not to post this separate comment on regulations.gov in deference to the ongoing peer-review publication process. However, we hope the resources provided in this comment can still be useful to inform CEQ's thinking as the agency finalizes this guidance and future NEPA regulations, to support the potential future incorporation of integrated scientific tools into practice. We would be pleased to discuss this promising tool with you or your staff further following review of the attached comment and materials. If there are any questions, please do not hesitate to reach out to either of us at the emails provided below with any questions. Sincerely, Michele Bustamante, Ph.D. Staff Scientist NATURAL RESOURCES DEFENSE COUNCIL mbustamante@nrdc.org Ann Alexander Senior Attorney NATURAL RESOURCES DEFENSE COUNCIL aalexander@nrdc.org

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