NEPA and State NEPA EIS Resource Center
Environmental Impact Statements that Include Discussions of Climate Change-Related Impacts
The Center for Climate Change Law has prepared two databases of environmental impact statements (EISs) that include consideration of climate change-related impacts. The databases include categories for the locality, lead agency, type of project, and a discussion of the impacts considered, as well as a categorization of the type of climate change-related impact considered for each project.
- The second database includes EISs submitted under the California Environmental Quality Act, and covers the period from July 1, 2009 to July 7, 2010.
Download the database (.xlsx)
Download the database (.xls)
A summer 2012 white paper by CCCL undergraduate intern Patrick Woolsey summarizes CCCL's findings on the types of climate change impacts being considered in EISs and highlights the differences among agencies in their climate analyses: White Paper on the Consideration of Climate Change in Federal EISs, 2009-2011 (July 2012), by Patrick Woolsey
The Center for Climate Change Law has also prepared a matrix summarizing the impacts discussed in EISs prepared by various federal agencies.
Environmental Impact Statements that Include Discussions of Water Impacts
The Center for Climate Change Law has compiled a database examining the treatment of water-related issues in all Final Environmental Impact Statements (EIS) reported to EPA from January 1 to September 30, 2012. The database, comprised of 149 FEISs, details the extent to which federal agencies address topics related to water and climate change.
Download the database (.xlsx)
A spring 2013 white paper by CCCL undergraduate intern Cathy Li summarizes the findings on types of water impacts being considered in EISs and highlights the differences among agencies in their treatment of the issue: Discussion of Climate Change-Related Water Impacts in Federal Environmental Impact Statements (EISs), January-September 2012 (March 2013).
Searching and Contextualizing EISs
Below are useful sites that can be used to search and understand environmental impact statements (EISs).
- The Environmental Impact Statement Database is a searchable index dating back to 2004 that allows EISs to be found by name, date, and lead agency. Also included online are comment letters issued by the Environmental Review Office, which assess submitted EIS drafts and offer recommendations on how to clarify and minimize impacts.
- NEPAssist is an innovative data-sharing tool recently created by the EPA, which allows reporters and the public to visualize relevant information associated with environmental impact reviews. The interactive map provides geographic, demographic, environmental, and economic context to EIS project information for specific sites or regions.
- The EPA’s Environmental Justice Geographic Assessment Tool, referred to as EJView, can be used in conjunction with NEPAssist. EJView utilizes various demographic, health, and facility data sets to map out potential effects on the public and environmental health of a community.
Environmental Assessment Protocols for the Consideration of Climate Change
Climate Change – Model Language in Transportation Plans, Federal Highway Administration, May 13, 2010
This document provides advice and excerpts from model transportation plans for agencies seeking to incorporate climate change into their plans in lieu of federal guidance. It is meant for states’ departments of transportation (DOTs) and metropolitan planning organizations (MPOs).
Secretarial Order 3226, U.S. Department of the Interior, Feb. 22, 2010
In section 3(a), the memo establishes “Climate Change Planning Requirements,” mandating consideration of climate change impacts in plans involving the use of the Department’s resources. The requirements apply equally to bureaus within the Department.
Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse Gas Emissions, Council on Environmental Quality, Feb. 18, 2010
The National Environmental Policy Act (NEPA) guidance would require federal agencies to calculate their projects’ greenhouse gas (GHG) emissions if the emissions are anticipated to exceed 25,000 metric tons of carbon dioxide equivalent per year. The draft guidance is currently under review.
Climate Change Considerations in Project Level NEPA Analysis, US Forest Service, Jan. 13, 2009
This guidance is intended to achieve consistency across the agency for dealing with climate change in projects’ Environmental Impact Statements (EISs), and as such is set of recommendations rather than rules.
Integrating Climate Change into the Transportation Planning Process, Federal Highway Administration, July 2008
This guide predates “Climate Change – Model Language in Transportation Plans.” In addition to that guide’s features, it covers the inclusion of climate change in existing transportation plans, quantification of GHG impacts in transportation plans, GHG mitigation strategies in transportation planning, and climate change adaptation in transportation planning. It was written to promote the incorporation of climate change in transportation planning.
CEQA Guidelines Amendments, California Natural Resources Agency, Dec. 30, 2009
The amendments made to the California Environmental Quality Act (CEQA) mandate that lead agencies evaluate to what degree their project’s direct and indirect GHGs impact the environment, whether the emissions exceed a threshold of significance, if they conflict with existing plans to reduce GHG emissions, and what measures may be taken to reduce significant impacts. The guidelines apply to nearly all projects in the state. Background and justification for the amendments is provided in the California Natural Resources Agency’s Final Statement of Reasons for Regulatory Action: Amendments to the State CEQA Guidelines Addressing Analysis and Mitigation of Greenhouse Gas Emissions Pursuant to SB97, Dec. 2009.
CEQA Air Quality Guidelines and Adopted Air Quality CEQA Thresholds of Significance, Bay Area Air Quality Management District, June 2, 2010
The Bay Area Air Quality Management District’s Air Quality Guidelines provide recommended procedures for evaluating potential air quality impacts in the Bay Area consistent with CEQA requirements, while the Adopted Air Quality CEQA Thresholds of Significance establish triggering levels of a range of pollutants, including but not limited to, carbon dioxide.
Preliminary Draft Staff Proposal: Recommended Approaches for Setting Interim Significance Thresholds for Greenhouse Gases Under the California Environmental Quality Act, California Air Resources Board (CARB), Oct. 2008
In this proposal, CARB recommends that threshold levels and types (whether quantitative, qualitative, or performance-based) be tailored on a sector-by-sector basis. The draft is still under review and is not binding.
CEQA and Climate Change: Addressing Climate Change Through California Environmental Quality Act (CEQA) Review, Governor’s Office of Planning and Research (OPR), June 2008
This document served as California’s interim technical guidelines for incorporating climate change into CEQA project planning. It was intended for use by professional planners, land use officials, and CEQA practitioners. The guidelines provided OPR’s perspective, and served as optional recommendations until the CEQA Guidelines Amendments took effect.
Addendum to the 2007 Regional Transportation Plan Guidelines: Addressing Climate Change and Greenhouse Gas Emissions During the RTP Process, California Transportation Commission, May 2008
This addendum was requested by the State Senate to incorporate climate change into Regional Transportation Plans (RTPs), which, like projects, are reviewed under CEQA. The best practices identified are not required by law, but MPOs and regional transportation planning agencies (RTPAs) are “strongly encouraged” to follow them.
CEQA and Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act, by California Air Pollution Control Officers Association (CAPCOA), Jan. 2008
This “resource guide” explicitly states that it is not a guidance document and is not intended to direct agencies on how to consider GHGs, but instead to provide information about elements of CEQA that are pertinent to GHG consideration. It is written to assist agencies as they establish procedures for evaluating projects’ GHG emissions under CEQA.
Addressing Climate Change in NEPA and CEQA Documents, Climate Change Focus Group, Aug. 2007
This independent analysis provides a framework with which to address climate change in the NEPA and CEQA review process. It explores five approaches that project proponents may choose to use absent regulatory guidance.
Alternative Approaches to Analyzing Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Association of Environmental Professionals, June 2007:
This independent analysis provides a framework with which to address climate change in the CEQA review process. It explores eight approaches that project proponents may choose to use to address climate change absent regulatory guidance.
Recommendations by the Association of Environmental Professionals (AEP) on How to Analyze Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Association of Environmental Professionals, March 2007
This independent analysis provides a framework with which to address climate change in the CEQA review process. It explores six approaches that project proponents may choose to use to address climate change absent regulatory guidance.
Revised MEPA Greenhouse Gas Emissions Policy and Protocol, Massachusetts Executive Office of Energy and Environmental Affairs, May 5, 2010
The Massachusetts Environmental Policy Act (MEPA) GHG Policy requires all projects that must already file an EIR, excluding those qualifying for a de minimis exception, to enumerate their direct and indirect GHG emissions and evaluate mitigation measures. The protocol does not establish significance thresholds, but instead considers projects’ emissions and mitigations options on a case-by-case basis. Additional information can be found here.
General Guidance for Carbon Footprint Development in Environmental Review, Minnesota Pollution Control Agency (Sept. 2009)
This guidance provides instruction on incorporating climate change into Minnesota’s state-equivalent of NEPA EISs, Environmental Assessment Worksheets (EAWs). It applies to “proposers of projects that must obtain both an air emissions permit and also complete environmental review.” These proponents must determine the carbon footprint of their project by using the Climate Registry’s General Reporting Protocol guidelines for Scope 1 and Scope 2 categories (direct and indirect GHG emissions). The guidance also provides alternative methodologies for various emissions source categories, Minnesota-specific CO2 emission factors, and the emissions rates of the state’s largest electricity providers.
How to Prepare an Environmental Assessment Worksheet for the MPCA, Minnesota Pollution Control Agency (MPCA) (May 2007)
This is the original guidance for Minnesota EAWs that mention GHGs. Question 23 requires that the “type, sources, quantities and compositions” of GHGs be included among stationary source air emissions. It also requires that the project proponents describe “any proposed pollution prevention techniques and proposed air pollution control devices,” as well as the “potential impacts from pollutants.” This policy applies whenever MPCA is “the Responsible Unit of Government for an EAW.”
The Environmental Manual (TEM), New York State Department of Transportation (NYSDOT) Engineering Division – Office of the Environment
The guiding document for the NYSDOT’s “policy, procedure and technical guidance on environmental matters relating to the planning, design, construction and maintenance of transportation facilities” is currently being updated and will begin to formally address climate change. According to the already-released table of contents, the new manual will include one section titled “project level energy and ghg analysis [sic]” and another named “TIP/Plan energy and ghg analysis [sic].” The two are likely to provide guidance for consideration of GHGs in projects and plans to be filed with New York’s State Environmental Quality Review Act (SEQRA).
Guide for Assessing Energy Use and Greenhouse Gas Emissions in an Environmental Impact Statement, New York State Department of Environmental Conservation (DEC), July 15, 2009
This guide is expressly intended to advise DEC staff on considering energy use and GHG emissions in SEQR EISs when DEC is the lead agency, though the guidance is believed to influence other agencies in assessing GHG impacts. It calls for the quantification of direct and indirect GHG emissions, and also provides methodological support for several common emissions sources.
SEQRA and Climate Change, The Municipal Art Society of New York, April 2009
This document makes a case for GHG analysis under SEQRA and advocates three protocols: “(1) a GHG Protocol; (2) a Protocol for Measuring the Impacts of Climate Change on an Action; and (3) an Energy Environmental Assessment Addendum.” It then explains how climate change should be considered in an EIS, including quantifying direct and indirect emissions, calculating emissions to the level of “total CO2e per user for each component of emissions,” conducting mitigation analysis, and evaluating climate change impacts on the project. The document’s proposed GHG Protocol was not officially adopted.
For New York City-specific guidance, see the Local Guidelines section below.
State Environmental Policy Act (SEPA) Guidance on Addressing Greenhouse Gas Emissions (GHG) Draft, Washington State Department of Ecology, May 27, 2010
With this draft policy, SEPA will require public agencies to assess GHG emissions “over [a project’s] lifetime including the construction phase,” evaluate climate change impacts on the project, identify feasible mitigation measures for emissions and impacts, and assess the “significance” of unmitigated emissions. The guidance is currently being amended or redrafted. Additional information can be found here.
Guidance for Project-Level Greenhouse Gas and Climate Change Evaluations, Washington State Department of Transportation (WSDOT) Environmental Services Office, Oct. 2010
This guidance is mandatory for all WSDOT projects preparing SEPA or NEPA EIS/EAs. It requires the quantitative analysis of operational and construction GHG emissions, and the qualitative consideration of embodied/lifecycle emissions for all EISs.
City of Orange, CA
Interim Guidance for Greenhouse Gas Emissions Analysis, City of Orange Community Development Department, April 2010
This guidance writes that “most CEQA documents for non-exempt projects in the City will be required to contain a quantitative analysis of GHGs using URBEMIS.” It also mandates that a project’s proponents discuss its consistency with “the goals, policies and implementation programs of the City’s 2010 General Plan related to GHGs.” Projects should abide by South Coast Air Quality Management District’s recommended “Tier 3” quantitative thresholds. Mitigation measures should be pursued to reduce significance below these thresholds.
New York City, NY
2010 CEQR [City Environmental Quality Review] Technical Manual, Mayor’s Office of Environmental Coordination, May 2010
The guidance may require a GHG emissions assessment for projects that already require an EIS and propose generating power, altering the city’s solid waste management system, or creating a development of at least 350,000 square feet, but decisions are made by lead agencies on a case-by-case basis. It mandates and provides resources to assist estimating indirect and direct operations emissions, mobile source emissions, construction emissions, and emissions from solid waste management. Next, the GHG emissions and mitigation measures must be evaluated relative to the City’s GHG reduction goal for 2030. The guidance is now in effect. Additional information can be found here.
King County, WA
Evaluation of Climate Change Impacts Through the State Environmental Policy Act, King County Executive, Aug. 31, 2007
The executive order mandates that all King County departments evaluate climate change impacts when they are the lead agency in a project subject to SEPA.
Bay Area Air Quality Management District (BAAQMD)
CEQA Guidelines, BAAQMD, June 2010
This document contains the following relevant sections:
- Chapter 2.2 – Thresholds of Significance: Greenhouse Gases – Project Level
- Chapter 4.2 – Operational-Related Impacts: Greenhouse Gas Impacts
- Chapter 8.2 – Construction-Related Impacts: Greenhouse Gases
- Chapter 9.2 – Plan-Level Impacts: Greenhouse Gases
It establishes thresholds of significance and steps for significance determination for lead agencies within its district.
Final CEQA Thresholds of Significance, BAAQMD, June 2, 2010
This is a two-page chart containing emissions thresholds for various air pollutants. It has operational-related GHG emissions thresholds at the project level, the plan level, and the regional plan level.
Proposed Air Quality CEQA Thresholds of Significance, BAAQMD, Dec. 7, 2009
This is the complete proposal for the CEQA fuidelines regarding GHGs. It provides justification for revising the emissions thresholds.
Sacramento Metropolitan Air Quality Management District (SMAQMD)
CEQA Guide, SMAQMD, Dec. 2009
This guide provides expectations of analysis in line with state suggestions, a list of common methodologies, instructions for considering direct and indirect GHG emissions, and recommendations that the threshold of significance for GHG emissions be related to AB 32’s GHG reduction goals.
San Joaquin Valley Air Pollution Control District (SJVAPCD)
District Policy – Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA Review When Serving as the Lead Agency, SJVAPCD, Dec. 17, 2009
This report introduces the idea of Best Performance Standards (BPS), to be established by district staff for specific classes and categories of stationary sources, as a means to a less than significant impact on climate change and a streamlined analysis process. Only projects that do not implement BPS “would require quantification of project specific GHG emissions.” The document then advises on establishing business-as-usual and baseline comparisons and determining project significance. This policy applies explicitly to the district staff when it serves as the lead agency in a project, but the guidelines are influential locally.
South Coast Air Quality Management District (SCAQMD)
Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold [links to self-executing .exe file], SCAQMD, Oct. 2008
This guidance document proposes that the interim GHG significance thresholds be the Tier 3 screening level, at which 90% of total GHG emissions from new or modified stationary sources would be subject to some level of CEQA analysis. It also provides recommendations for analyzing GHG emissions in CEQA documents and features a table comparing CARB’s and AQMD’s Interim GHG Significance Thresholds Approaches. Additional information can be found here.
Northern Territory Government Environmental Impact Assessment Guide: Greenhouse Gas Emissions and Climate Change, Department of Natural Resources, Environment, the Arts and Sport of the Northern Territory Government, July 2, 2009
This guidance requires that project proponents estimate GHG emissions from the construction and operation phases, detail “the project lifecycle greenhouse gas emissions and the greenhouse gas efficiency of the proposed project (per unit and/or other agreed performance indicators),” ,and demonstrate consideration of efficiency and mitigation measures. Offsets are encouraged if they take place within the Northern Territory. A program must be outlined “which includes ongoing monitoring, investigation, review and reporting of greenhouse gas emissions and abatement measures.” Lastly, the impacts of climate change on the project must be considered. It appears that all projects must adhere to these guidelines.
A Guide for Incorporating Adaptation to Climate Change into Land Use Planning, CEF Consultants Ltd and CBCL Limited, Nov. 2005
This guide is designed to help “land use planners to incorporate adaptation to climate change within municipal planning strategies.” It provides guidance in approaches municipalities may take to incorporate climate change into land use planning.
Incorporating Climate Change Considerations in Environmental Assessment: General Guidance for Practitioners, The Federal-Provincial-Territorial Committee on Climate Change and Environmental Assessment (Canada), Nov. 2003
This document was written “to provide environmental assessment (EA) practitioners with general guidance for incorporating climate change considerations in project EA.”
Incorporating Climate Change into the Environmental Impact Assessment Process – Practitioner's Guide, ClimAdapt, June 2003
This guidance aims to assist EIA practitioners assess climate change implications and incorporate climate change considerations into the EIA process.
Report on the application and effectiveness of the Environmental Impact Assessment Directive, European Commission, July 2009
In 2009, the European Commission issued a review of the Environmental Impact Assessment Directive in which it set a goal to develop guidelines for the integration of climate change impacts in EIAs by 2011.
Natural Resources, Environmental Management, Hazard Risk Reduction and Climate Change. Jamaican Ministry of the Environment, 2009
This report outlines a National Action Plan which calls for the inclusion of climate risk analysis in Environmental Impact Assessments.
Adaptation Handbook: Undertaking Risk Treatment for Coastal Climate Change Risks in the Republic of Kiribati. Kiribati Adaptation Project, 2009
This manual provides guidance for the inclusion of climate change risk assessment in environmental planning processes for coastal projects.
Climate Change in Water Management, Netherlands Commission for Environmental Assessment, 2010
This report outlines the role of Environmental Impact Assessments in addressing climate change risks and adaptation involving water projects.
Climate Change Effects and Impacts Assessment: A Guidance Manual for Local Government in New Zealand, Ministry for the Environment, May 2008
This guidance is designed “to help local governments identify and quantify opportunities and hazards that climate change poses for their functions, responsibilities, and infrastructure.”
Spanish National Climate Change Adaptation Plan, Spanish Ministry of Environment, 2006.
This plan calls for for the development of guidelines and regulations to incorporate the foreseen impacts of climate change into the Environmental Impact Assessment process.
UK / Wales
Strategic Environmental Assessment and Climate Change: Guidance for Practitioners, Environment Agency, Countryside Council for Wales, English Nature, UKCIP, Levett-Therivel Sustainability Consultants, CAG Consultants and the Environmental Change Institute, June 2007
This guide presents ways climate change impacts and mitigation measures can be described and evaluated in Strategic Environmental Assessments. An earlier edition is available here.
Climate Change Impacts and Spatial Planning Decision Support Guidance, ESPACE (European Spatial Planning: Adapting to Climate Events) and UK Environment Ministry, June 2008.
This report presents guidance for land use planners in carrying out climate change risk assessments, emphasizing adaptation. It outlines analytical tools created under the UK Climate Impacts Program (UKCIP) which could be applicable to other northern European countries.
International Development Organizations
Caribbean Development Bank
Sourcebook on the Integration of Natural Hazards into the Environmental Impact Assessment Process, Caribbean Community Adaptation to Climate Change in the Caribbean (ACCC) Project and the Caribbean Development Bank, 2004
This report, produced with support from the Canadian International Development Agency and USAID, outlines recommendations for the integration of climate change considerations into environmental impact assessment.
Inter-American Development Bank
Analytical Framework for Climate Change Action. Inter-American Development Bank, March 2010
This manual includes recommendations for addressing climate change vulnerability in the bank’s risk assessment activities for development programs.
Organization for Economic Cooperation and Development (OECD)
Incorporating Climate Change Impacts and Adaptation in Environmental Impact Assessments, Organization for Economic Cooperation and Development, 2010
This report examines ways that climate risk assessment can be integrated into EIA processes, and includes an overview of the policies that various national governments have adopted on climate change impacts in EIAs.
United States Agency for International Development (USAID)
Adapting to Climate Vulnerability and Change: A Guidance Manual for Development Planning, United States Agency for International Development, August 2007
This manual outlines the procedure for integrating the assessment of climate risk and vulnerability into the USAID project planning and review process.
The World Bank
World Bank Group Development and Climate Change: A Strategic Framework for the World Bank Group, The World Bank, 2008
This report provides guidelines for the inclusion of climate risk in environmental assessments undertaken for World Bank development programs.
CCCL would like to acknowledge the work of Brenden Cline, who compiled the resources on this page and created the NEPA and CEQA spreadsheets linked above. To comment on this page or offer suggested materials, please email Bradford McCormick.
 Note: Two authors are involved in each of the following white papers: “Addressing Climate Change in NEPA and CEQA Documents,” “Alternative Approaches to Analyzing Greenhouse Gas Emissions and Global Climate Change in CEQA Documents,” and “Recommendations by the Association of Environmental Professionals (AEP) on How to Analyze Greenhouse Gas Emissions and Global Climate Change in CEQA Documents.” Each document is similar, but offers nuanced results rather than a single progression of thought.