Qualification of Soft Costs of the US Federal Guidance When Considering Greenhouse Gas Emissions and the Effects of Climate Change in NEPA Reviews

摘要

A notice by the Council of EnvironmentalQuality (CEQ) was published on December 14, 2014 regarding the revised “DraftGuidance for Federal Departments and Agencies on Consideration of GreenhouseGas Emissions and the Effects of Climate Change in NEPA Reviews”. The review ofthis 2014 draft guidance suggested increased analysis, work, review andapprovals required by the State Department of Transportation (DOT) and FederalHighway Administration (FHWA) working with and on behalf of local publicagencies (LPAs) in order to authorize and obligate roadway projects funded withfederal-aid money. All federal-aid-funded roadway projects require a NEPAanalysis to be done on the action (project) and an environmental clearancedocument to be obtained prior to finalizing the design. The 2014 draft guidancemay complicate an already lengthy and often critical path activity for roadwayprojects requiring NEPA documentation.