The White House Council for Environmental Quality (CEQ) has released a draft of revised guidance that “describes how Federal departments and agencies should consider the effects of greenhouse gas emissions and climate change” under reviews governed by the National Environmental Policy Act (NEPA)—an act which basically requires some sort of assessment as to the environmental impacts of all proposed federal actions.

Under the revised guidance, the CEQ makes it clear that they want federal agencies now to include the impact on climate change in their environmental assessments.

But here’s the kicker, the CEQ doesn’t want the climate change impacts to be described using measures of climate—like temperature, precipitation, storm intensity or frequency, etc.— but rather by using the measure of greenhouse gas emissions.

Basically, the CEQ guidance is a roadmap for how to circumvent the NEPA requirements.

Here is how the CEQ characterizes the intent of the NEPA:

NEPA is designed to promote disclosure and consideration of potential environmental effects on the human environment resulting from proposed actions, and to provide decisionmakers with alternatives to mitigate these effects. NEPA ensures that agencies take account of environmental effects as an integral part of the agency’s own decision-making process before decisions are made. It informs decisionmakers by ensuring agencies consider environmental consequences as they decide whether to proceed with a proposed action and, if so, how to take appropriate steps to eliminate or mitigate adverse effects. NEPA also informs the public, promoting transparency of and accountability for consideration of significant environmental effects. A better decision, rather than better—or even excellent—paperwork is the goal of such analysis.

Clearly, the emphasis of NEPA is on the “environment” and better informing policymakers and the public as to the potential impacts of proposed federal actions on the environment.

But here is how the CEQ summarizes the intent of its new guidance:

Agencies should consider the following when addressing climate change:

(1) the potential effects of a proposed action on climate change as indicated by its GHG emissions;

This is represents a fundamental scientific error—greenhouse gas (GHG) emissions are not themselves a measure of an “environmental effect” nor are they an indicator of “climate change.”

This misdirection—one inconsistent with the NEPA— immediately caught our attention and we developed and submitted a Comment on the CEQ guidance that pointed out this glaring error. The public comment period, which originally closed yesterday, has been extended until March 25, 2015.

The sense of our Comment was by cloaking climate change impacts in the guise of greenhouse gas emissions serves not to “promote transparency,” or “inform decisionmakers” and “the public” but rather has the opposite intent—misdirection and misinformation.

Why does the CEQ seek to limit the climate change discussion to greenhouse gases?

In light of the difficulties in attributing specific climate impacts to individual projects, CEQ recommends agencies use the projected GHG emissions and also, when appropriate, potential changes in carbon sequestration and storage, as the proxy for assessing a proposed action’s potential climate change impacts. This approach allows an agency to present the environmental impacts of the proposed action in clear terms and with sufficient information to make a reasoned choice between the no-action and proposed alternatives and mitigations, and ensure the professional and scientific integrity of the discussion and analysis.

They got the first part right. The reason it is “difficult” is not because tools don’t exist—after all that’s what climate models have been developed for, to take carbon dioxide emissions and covert them to environmental impacts—but rather that any attempt to run the emissions through such climate models would show they would have no detectable impact.

In other words, it would prove that the assessment of climate change impacts of federal actions, as directed by the CEQ, to be a complete and utter waste of time.

How do we know this? Because even a complete cessation of all greenhouse gases from the U.S. starting tomorrow and running forever would only serve to avert somewhat less than 0.15°C of future global temperature rise between now and the end of the century—an amount that is environmentally insignificant. Lesser actions will have lesser impacts; you can see for yourself here.

This is the last thing the White House wants federal agencies to conclude. So instead of assessing actual climate impacts (of which there are none) of federal actions, the CEQ directs agencies to cast the effect in terms of greenhouse gas emissions—which can be used for all sorts of mischief.  For example, see how the EPA uses greenhouse gas emissions instead of climate change to promote its regulations limiting carbon dioxide emissions from power plants.

No doubt this is the type of analysis that the CEQ has in mind—one which seeks to elevate policy initiatives (like the Climate Action Plan) above hard scientific analysis.

Here is how we concluded our Comment to the CEQ:

To best serve policymakers and the general public, the CEQ should state that all but the largest federal actions have an undetectable and inconsequential impact on the environment through changes in the climate. And for the largest federal actions, an analysis of the explicit environmental impacts resulting from greenhouse gas emissions arising from the action should be detailed, with the impacts assessment not limited to climate change but also to include other environmental effects such as impacts on overall vegetative health (including crop yield and production).

As called for in the guidelines described in this current draft—substituting greenhouse gas emissions for climate change and other environmental impacts—is not only insufficient, but is scientifically inadequate and potentially misleading. As such, these CEQ guidelines should be rescinded and discarded.

Our Comment, in its entirety, is available here.