TEMPLATE for GHG emission Analysis and Climate Change for NEPA Documents for STATE DOTs
Background For purposes of the National Environmental Policy Act (NEPA) process, Federal agencies have initiated efforts on how to assess the impacts of potential GHG emissions from proposed Federal actions and how to consider opportunities to reduce their CO2 footprint, as well as adapt the proposed actions to climate change impacts. On August 1, 2016, Council on Environmental Council (CEQ) issued Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews (81 FR 51866). However, on April 5, 2017, the Council on Environmental Quality (CEQ) withdrew the guidance (82 FR 16576). Despite the repeal of these Federal rules, DOTs must still comply with a variety of state and local requirements for the consideration of GHG emissions in transportation projects. Currently, there are no guidance for DOT’s to do so. Additionally, a future Federal administration may reissue requirements similar to those recently rescinded, reimposing burdens on state DOTs for assessing potential impacts in GHG emissions and climate change. Under NEPA, the impact of climate change may be assessed on a project because change is occurring and some of the changes are reasonably foreseeable. On the other hand, trying to determine the effect of an individual project on climate change (i.e., project level GHG emissions analysis) is not reasonably foreseeable because the attribution of an individual transportation project’s build/no-build emissions to specific climate change impacts is negligible. This means the GHG emissions difference between alternatives is also negligible in terms of potential impacts of the project. However, some DOTs are calculating GHG emissions and/or assessing potential impacts related to climate change as part of NEPA. This research idea is therefore seeking guidance, templates and direction on how to conduct both analyses in a streamlined yet appropriate way that state DOTs could adopt or otherwise apply at minimal cost or effort. NEPA is intended to “concentrate on the issues that are truly significant to the action in question, rather than amassing needless detail” (40 CFR 1500.1(b)). “The NEPA process is intended to help public officials make decisions that are based on understanding of environmental consequences, and take actions that protect, restore, and enhance the environment (§1500.1(c))”. Agencies should “identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (§1506.3), narrowing the discussion of these issues in the statement to a brief presentation of why they will not have a significant effect on the human environment or providing a reference to their coverage elsewhere (§1501.7(3)). Research Problem statement This proposed research project would develop an approach and support materials to address on-road transportation GHGs emissions and potential impacts to climate change in NEPA documents. Work completed by states to date would be reviewed to identify the best approaches developed across the country. One focus would be to identify how state DOTs can address GHG emissions associated with operation, construction (including materials, detours, etc.), and maintenance, within a reasonable level of effort. In addition, the proposed study would also create templates to address climate change in NEPA documents. Research Objective 1. Characterize the current state of practice a. Determine which DOTs are conducting quantitative GHG analyses and/or addressing climate change issues during the NEPA process. As appropriate, build on survey work done for NCHRP 25-56. b. Identify how DOTs are addressing GHG emissions: i. Qualitative vs quantitative ii. Operational, construction, maintenance, including lifecycle considerations iii. Tools and methods and best practices (MOVES, FHWA’s ICE tool, etc.) c. Identify additional GHG emission analysis methods that may be of use to state DOTs. 2. Summarize current information a. Create a resource document that identifies completed transportation GHG NEPA analyses, guidance documents, and relevant tools. b. Develop tables that compare GHG effects from project operation, construction, and maintenance. c. Develop tables that compare mitigation methods being proposed. d. Identify situations in which a project-level GHG analysis is effectively supporting decision making and situations where the analysis is done for disclosure purposes. Can we draw conclusions about the types of projects where a project-level GHG analysis is meaningful? e. Identify approaches that could be applied for streamlined analyses that state DOTs could adopt at relatively low cost and level of effort. 3. Develop template, document and direction a. Develop templates to present project-level GHG analysis in NEPA documents (EA, EIS). Templates should have options to support a variety of project types, including low volume projects with little effect on GHGs. Templates language will address where to discuss GHGs be it in air quality section or direct, indirect versus cumulative impacts. b. Develop template text to address climate change in NEPA documents by region across the US. The template language could address mitigation necessary to protect project from future climate change effects. c. Develop document that compiles all of the best means and methods of DOTs. 4. Information collection and dissemination a. The project could include a peer exchange to better understand the direction DOTs will like to take in the absence of federal rules and guidance regarding GHGs and analysis experience to date. b. The research products would include a report template and compendium of current guidance and completed project-level analyses for use by DOTs and their consultants as they prepare assessments for GHG emissions and potential impacts related to climate change in NEPA documentation.
The potential payoff of this research is that it would provide a streamlined approach to addressing GHGs and climate change in NEPA at a relatively low cost and level of effort for DOTs. Note – A pooled fund research project is currently underway to update and expand FHWA’s ICE tool. Work reflecting this tool should be coordinated with the pooled fund study.
Senior Policy Specialist - Air Quality and Climate
Washington State Department of Transportation
June 4, 2019
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