Comments Submitted for the Record Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act.
March 10, 2020
NEPA scrutiny of project-related greenhouse gas emissions are neither required by law nor are good policy.
The NEPA process has been used by environmentalists to hold up critical infrastructure projects and to halt economically and environmentally valuable resource management on public lands. Forcing companies to account for the impossible to know future impacts of greenhouse gas emissions whether directly or only distantly and tangentially related to a project under consideration is neither required by the law, nor justified as a matter of sound policy.