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Climate Change and Environmental Impact Statements

As ClimateWire reported (available via nytimes.com) the other week, government agencies are struggling with how to fit climate change into the process of environmental review (such as for licensing energy facilities or expanding offshore oil drilling). At one level, this is a no-brainer. Greenhouse gases contribute to climate change, and climate change is the biggest environmental impact of all.

But as always, the devil is in the details. The direct use of fossil fuels resulting from a project should usually be easy to figure out. Adding the "embodied carbon" in construction materials is a bit trickier. Going beyond that, there are indirect carbon impacts. For instance, a federal action that decreases soybean acreage in the United States could raise the price of soybeans and encourage farmers in Brazil to cut down rain forest in order to plant more beans.

There's also the question of when a climate impact becomes "significant," which is the trigger under the National Environmental Policy Act (NEPA) for a full-scale environmental impact statement. From one perspective, almost nothing is significant when measured against total global greenhouse gas emissions. But that's the wrong perspective.

Think of this from an economic perspective. A relatively conservative estimate of the harm done by a ton of carbon is $50. Many of us have qualms about whether this economic analysis really captures the dangers of climate change, but at least it sets a floor. By this measure, licensing a single power plant counts as having a "significant" impact.

Here's the math: The average coal-fired plant emits about 4 million tons of C02 per year, which translates into about 1.3 million tons of carbon. And that translates into $65 million of harm per year, even by the stingiest estimate -- which should certainly count as significant. In fact, as economists count these things, this is about the same harm as killing ten people per year!

There's another important dimension of NEPA that wasn't mentioned in the ClimateWire article. Besides the effect of federal actions on climate change, we also need to think about the effect of climate change on federal projects. It makes no sense to build a sea wall without taking into account the rising sea level caused by climate change.

It appears that the White House Council on Environmental Quality (CEQ) is getting ready to address these issues. Federal agencies tend to view environmental impact statements as an impediment rather than a way of better understanding their choices. That makes it all the more important for CEQ to push agencies in the direction of broader analysis of climate issues.

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Daniel Farber | April 17, 2009

Climate Change and Environmental Impact Statements

As ClimateWire reported (available via nytimes.com) the other week, government agencies are struggling with how to fit climate change into the process of environmental review (such as for licensing energy facilities or expanding offshore oil drilling). At one level, this is a no-brainer. Greenhouse gases contribute to climate change, and climate change is the biggest […]

Nina Mendelson | April 16, 2009

An Attack on Waxman-Markey That’s a False Alarm

On Friday, the Washington Times went A1 above-the-fold with “Climate bill could trigger lawsuit landslide.” Environmentalists say the measure was narrowly crafted to give citizens the unusual standing to sue the U.S. government as a way to force action on curbing emissions. But the U.S. Chamber of Commerce sees a new cottage industry for lawyers. […]

Matt Shudtz | April 15, 2009

New CPR Paper: Regulatory Preemption and Its Impact on Public Health

Avery DeGroh, a three-year old from Illinois, had a defibrillator implanted in her heart to deal with a congenital condition called “long QT syndrome.” It was a brand-new model with a specially designed wire (or “lead”) that is thinner and easier for doctors to install. Unfortunately, due to a problem with the new lead, one […]

Rena Steinzor | April 14, 2009

The People’s Agents: Rewarding Polluters with a Plaque on the Wall

Say you live in an urban neighborhood where crime is worrisome but not overwhelming. The police are chronically understaffed, with no money to walk the beat, and instead depend on what we might call a “deterrence-based enforcement system” – making high-profile arrests, prosecuting the worst violators, and relying on the resulting publicity to frighten others […]

Yee Huang | April 13, 2009

Water Buffaloes Ready to Charge… Over the Rain?

A recent article in the Los Angeles Times described the latest absurdity in the never-ending search to quench the thirst for water: ownership of rainwater and, more precisely, the illegality of rainwater harvesting.  Residents and communities in parts of Colorado are turning to this ancient practice of collecting and storing rain to fulfill their domestic […]

William Buzbee | April 10, 2009

Waxman-Markey: Federalism Battles

On Tuesday, March 31, House Energy and Commerce Committee Chairman Henry Waxman (D-CA) and Rep. Edward Markey (D-MA) released a “discussion draft” of the American Clean Energy and Security Act of 2009 — a climate change bill that will serve as the starting point for long-delayed congressional action on the world’s most pressing environmental program. […]

James Goodwin | April 8, 2009

Climate Change: Endangering Our Future, Destroying Our Past

The large earthquake that struck central Italy on Monday is devastating not only for the immense human suffering—people killed and injured, and communities disrupted—but also for the priceless losses of Italian cultural heritage.  The Italian Ministry of culture has reported that the earthquake damaged a number of buildings of immeasurable historical significance, including the Basilica di […]

Ben Somberg | April 7, 2009

Waxman-Markey: Adaptation

On Tuesday, March 31, House Energy and Commerce Committee Chairman Henry Waxman (D-CA) and Rep. Edward Markey (D-MA) released a “discussion draft” of the American Clean Energy and Security Act of 2009 — a climate change bill that will serve as the starting point for long-delayed congressional action on the world’s most pressing environmental program. […]

Holly Doremus | April 6, 2009

EPA Asserts Itself on Mountaintop Removal Mining

This item is cross-posted by permission from Legal Planet. EPA is finally flexing its muscle on mountaintop removal mining, taking on the Corps of Engineers and stepping in for states that have been reluctant to attack the practice. Mountaintop removal mining involves blasting the tops off of mountains, typically in Appalachia, to get at coal. […]