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Ensuring Robust Consideration of Climate Change Under NEPA

Six Priorities for CEQ’s Phase 2 Rulemaking

In April 2022, the Council on Environmental Quality (CEQ) finalized a limited, “Phase 1” rulemaking to restore several longstanding features of the regulations that guide agency assessments under the National Environmental Policy Act (NEPA) which CEQ had removed in 2020. In that rule, CEQ reaffirmed its intentions to further revise the regulations to better ensure that agencies make decisions that “advance environmental, climate change mitigation and resilience, and environmental justice objectives.” This policy brief outlines six simple regulatory revisions that CEQ should prioritize for its “Phase 2” rulemaking to improve consideration of climate change during environmental review. Each of the following suggestions is consistent with the purpose, structure, and text of NEPA and will better ensure that environmental review includes consideration of how a proposed action may worsen climate change and how climate change may negatively impact a proposed action and the environment affected by the action.