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  • Comments to EPA on Draft Revision of Technical Guidance for Assessing Environmental Justice in Regulatory Analysis

    EPA seeks comments on the it's Draft Revised EJ Technical Guidance, which highlights technical approaches that analysts can use to evaluate environmental justice concerns in regulatory actions. The Institute for Policy Integrity's comments to the agency advocate for enhanced documentation and transparency in environmental justice assessments.

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  • Comments to CEQ on Phase One of the Environmental Justice Scorecard

    The Council on Environmental Quality (CEQ) recently published Phase One of the Environmental Justice Scorecard (Scorecard), which evaluates federal agencies' progress on advancing the Justice40 Initiative, implementing and enforcing environmental and civil rights laws, and institutionalizing environmental justice. CEQ sought public feedback on the Scorecard’s usability and potential qualitative and quantitative metrics to improve future iterations of the Scorecard. The Institute for Policy Integrity submitted comments recommending several changes to enhance transparency, accountability, and comprehensiveness.

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  • Supplemental Comments to CEQ on Climate Change Guidance

    Earlier this year, the Council of Environmental Quality (CEQ) published interim guidance on analyzing climate change effects under the National Environmental Policy Act in which it endorsed using the social cost of carbon in environmental analysis. In this supplemental comment letter, we suggest that CEQ specifically endorse the Environmental Protection Agency’s newly-updated climate-damage values when it finalizes the interim guidance.

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  • Comments to CEQ on Proposed Revisions to NEPA Implementing Regulations

    In July, the Council on Environmental Quality proposed revisions to the implementing regulations under the National Environmental Policy Act. The Proposed Rule reflects a more holistic approach to informing agency decisions with a robust and balanced analysis of environmental impacts. In our comment letter, we suggested improvements to the proposal that would help ensure robust and balanced treatment of environmental impacts in NEPA reviews.

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  • Comments to Council on Environmental Quality on Interim Guidance on Considering Climate Change Under NEPA

    In January, the Council on Environmental Quality published interim guidance providing best practices to federal agencies on the consideration of climate change in environmental reviews conducted under the National Environmental Policy Act. The guidance provides helpful direction to agencies on assessing how proposed actions and their alternatives (1) will contribute to climate change through their greenhouse gas emissions; and (2) will potentially be affected or have their environmental consequences exacerbated by climate change impacts. Our comment commends CEQ on its thorough guidance and provides recommendations to strengthen both areas. 

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  • Comments to CEQ on the Environmental Justice Scorecard

    Policy Integrity submitted comments on White House Council on Environmental Quality's Environmental Justice Scorecard on behalf of the Environmental Justice Health Alliance (EJHA) and Coming Clean. EJHA and Coming Clean are made up of grassroots environmental justice groups, health organizations, environmental groups, community and neighborhood organizations and many more constituencies united in working towards a healthy, just and equitable present and future. The comments were also signed on to by over 20 grassroots organizations from around the country.

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  • Comments to CEQ on Carbon Capture, Utilization, and Sequestration Guidance

    The White House Council on Environmental Quality (CEQ) recently released interim guidance on Carbon Capture, Utilization, and Sequestration (CCUS) to assist federal agencies with regulation, permitting, and associated activities. We filed comments urging CEQ to update the guidance document with additional targeted recommendations for agencies on monitoring, reporting and verification (MRV) programs; project prioritization; and other topics.

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  • Comments to CEQ on Proposed Revisions to NEPA Regulations

    We submitted comments encouraging the Council on Environmental Quality (“CEQ”) to expand its legal and economic justification for its proposal to restore several key provisions to the regulations implementing the National Environmental Policy Act (“NEPA”) that were revised improperly in 2020. Our comments also suggest regulations and guidance that would promote the public welfare and enhance agency consideration of greenhouse gas emissions, climate risk, and environmental justice.

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  • Comments to CEQ on the National Environmental Policy Act

    The Council on Environmental Quality (CEQ) proposed changes to the regulations implementing the National Environmental Policy Act (NEPA), a decades-old statute that requires federal agencies to analyze the environmental impact of actions. We submitted comments explaining how the proposed rule runs afoul of the statute, drastically limiting agencies’ abilities to consider various effects and implement NEPA procedures. We also submitted joint comments detailing how the provisions would undermine analysis of climate effects, and encouraging CEQ to promote the use of the social cost of greenhouse gases.

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  • Comments to CEQ on NEPA and Greenhouse Gas Emissions

    The Council on Environmental Quality is proposing to revise its National Environmental Policy Act guidance on the consideration of greenhouse gas emissions. We submitted comments explaining how the draft guidance makes vague and misleading statements with respect to when and how agencies must analyze the greenhouse gas emissions associated with their project approvals. We encourage CEQ to correct errors and align the guidance with federal caselaw and existing regulations.

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