Policy Impacts

Strengthening Environmental Review

Policy Integrity has played a significant role in modernizing environmental reviews conducted under the National Environmental Policy Act (NEPA). Our input has helped shape regulations and guidance on these reviews, ensuring that federal agencies consider a broader range of expected impacts before approving projects or other actions.

In particular, our scholarship, reports, and comments have outlined the best practices for considering climate impacts under NEPA and offered specific suggestions to the Council on Environmental Quality (CEQ) for ensuring those best practices are used across federal permitting processes. CEQ subsequently adopted many of our recommendations in its NEPA regulations and guidance. For example, CEQ incorporated our recommendations for quantifying the full scope of greenhouse gas emissions, applying the social cost of greenhouse gases, and considering the impacts of climate change on proposed projects, among other suggestions.

Although recent court decisions and administrative actions will diminish CEQ’s role in guiding and standardizing agency environmental review, much of CEQ’s past guidance and regulations codified existing standards for agencies’ environmental review that developed in large part through litigation over permitting of federal energy projects. Policy Integrity played a key role in establishing that precedent through our amicus briefs, which have helped establish the need for the Federal Energy Regulatory Commission, Department of the Interior, and other federal agencies to rationally account for climate impacts in permitting decisions. These judicial precedents, which remain relevant for agencies’ environmental reviews, have become increasingly crucial given CEQ’s diminished role in the second Trump Administration.