Our comment primarily focuses on that aspect of the CEQ’s draft guidance which directs the use of greenhouse gas (GHG) emissions as a “proxy” for climate change in considering the environmental impacts of proposed federal actions in accordance with the National Environmental Policy Act (NEPA).
This aspect of the CEQ guidance is internally inconsistent, contrary to the intentions of NEPA, and ultimately misdirects policymakers and the general public alike.
Additionally, it illustrates a lack of understanding and comprehension of environmental science — yet this guidance is supposedly being developed to provide direction to federal agencies in their reporting of science-based environmental impacts.
Instead, the draft guidance appears to have been created to elevate policy initiatives over actual science. This is inappropriate. In its current form, the guidelines should be rescinded and redeveloped with a more appropriate emphasis on environmental and climate science.