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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 We submitted comments explaining how the draft guidance makes vague and misleading statements with respect to when and how agencies must analyze the greenhouse gas emissions associated with their project approvals.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. We also submitted joint comments detailing inaccuracies in the guidance.