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Comments to Highway Administration and Army Corps on Addressing Greenhouse Gas Emissions

We submitted comments to the Federal Highway Administration (FHWA) and the US Army Corps of Engineers (USACE) on recent draft environmental impact statements (EISs), in which we stressed the importance of addressing climate impacts of proposed projects.

The EIS makes a false claim—similar to the one made by the Forest Service in recent EISs—that project-level greenhouse gas emissions are too insignificant to contribute to climate change, and therefore not worth addressing. The US Army Corps EIS also fails to consider downstream emissions from oil drilling and fails to monetize damage from greenhouse gas emissions even though it monetizes other project effects. The FHWA EIS qualitatively discusses the general effects of greenhouse gas emissions, but does not mention climate change, much less quantify or monetize the effects of emissions from the project. In both sets of comments, we argue that addressing climate effects is required under NEPA and that Circular A-4 and best economic practices indicate that agencies should quantify and monetize greenhouse gas emissions.