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Erasing 'climate change' from federal agencies won't make it go away
As the world warms and people, wildlife and the natural environment suffer increasingly devastating impacts, the Trump administration is systematically erasing climate change from government regulations and policies.
The latest: In June 2019, the White House Council on Environmental Quality (CEQ) requested comments on draft guidance on how federal agencies should consider climate when they evaluate federal actions under the National Environmental Policy Act (NEPA). Incredibly, the phrase "climate change" does not appear in the document.
The intent could not be more clear: Federal agencies are encouraged to downplay and dismiss the risks of climate change, and to minimize consideration of greenhouse emissions in NEPA reviews. This is a fool's errand.
I was the assistant administrator for EPA's Office of Enforcement and Compliance Assurance for all eight years of the Obama administration, responsible for EPA's central role in NEPA reviews by other federal agencies. NEPA requires federal agencies to assess environmental impacts before making decisions on major federal actions, like pipeline permits, the management of federal land and the commitment of federal funds for highway construction. I worked closely with CEQ as well as other federal agencies as they conducted their required careful analyses of the environmental impacts of federal actions.
Science can't be dictated in political documents. Disparaging climate change won't prevent increasingly violent storms or more extreme heat. Flooding is not held at bay by words. Any dispassionate review of the science - including the 2018 National Climate Assessment - reveals that climate change is a danger to both people and the natural world. Erasing "climate change" from the CEQ guidance will not make it go away.
Fortunately, we still have a federal judiciary that believes that laws mean something and expects federal agencies to follow them. As the greatest environmental threat of our time, climate change is squarely within the NEPA directive to consider the impact of actions that significantly affect the quality of the human environment. Encouraging federal agencies to ignore the obvious, as CEQ's draft guidance is plainly intended to do, will only serve to tie up federal projects in the courts. Projects with obviously inadequate analysis of climate change will be delayed as federal agencies are forced to explain themselves and then sent back to the drawing board when those explanations are found wanting.
The guidance encourages agencies to diminish the importance of an individual project's greenhouse gas emissions by comparing them to national or sector wide emissions. This is how polluters have attempted to shirk responsibility for decades. NEPA is a common-sense law. Climate science and our common sense tell us that individually modest contributions collectively add up to catastrophe. The fact that a single project won't alone cause and can't alone fix climate change is not a basis to evade NEPA's obligation to rigorously consider its contribution.
As someone who worked for years to implement the noble goals of NEPA, my message to my federal colleagues is: Don't fall for it. You know where your legal and your moral obligations lie. If you don't robustly consider greenhouse gas emissions in your NEPA reviews - and evaluate means to reduce those emissions - you are very likely to face a federal judge who will question your choice. Your project and your credibility will both suffer.
I have no illusion that even a tsunami of public criticism will push this administration to adopt a more defensible approach to climate change. But professionals in the federal agencies know better. Do what the law requires. Quantify greenhouse gas emissions and evaluate alternatives to reduce them. That's your obligation under NEPA, no matter what any guidance may be urging you to do.
Cynthia Giles served as the assistant administrator for the EPA Office of Enforcement and Compliance Assurance (2009-2017). She is currently a guest fellow at the Harvard Environmental and Energy Law Program.