EIA Guidelines for Assessing the Impact of a Project on Climate Change

This page includes U.S. federal guidelines on how to assess the contribution of an action to climate change, as well as a sampling of state, local, and foreign protocols.


Federal Guidelines

Guidance on Consideration of Climate Change in NEPA Reviews, Council on Environmental Quality, August 1, 2016

This guidance describes how federal agencies should account for the effects of a proposal on climate change (using GHG emissions as a proxy for those effects) as well as the effects of climate change on the proposal.

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.

 

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.

Co-Benefits Risk Assessment (COBRA) Screening Model, Environmental Protection Agency, Updated June 2015

This free tool helps state and local governments estimate and map the air quality, human health and related economic benefits of clean energy policies and programs.


State Guidelines

California

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.

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.[1]

 

Massachusetts

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.

 

Minnesota

General Guidance for Carbon Footprint Development in Environmental Review, Minnesota Pollution Control Agency (March 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.”

 

New York

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.

 

Washington

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.


Local Guidelines

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

2012 CEQR [City Environmental Quality Review] Technical Manual, Mayor’s Office of Environmental Coordination, January 2012 (rev. 6/5/13)

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, May 2011

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, 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.


International Guidelines

Australia

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.

Canada

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.

European Union

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.

Jamaica

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.

Kiribati

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.

Netherlands

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.

 

New Zealand

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.”

 

Spain

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 PlanningUnited 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 GroupThe World Bank, 2008

This report provides guidelines for the inclusion of climate risk in environmental assessments undertaken for World Bank development programs.

 

SCCCL 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 ColumbiaClimate@gmail.com.


[1] 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.