Organizations Involved: Initiative on Climate Risk and Resilience Law, Environmental Defense Fund
Source: Federal Energy Regulatory Commission

Abstract

These comments recommend that the Federal Energy Regulatory Commission (FERC) supplement its draft policy statement on natural gas project reviews with additional guidance on the evaluation of climate impacts on projects under the National Environmental Policy Act (NEPA). Holistic, specific, and actionable climate impact analysis is necessary to meet NEPA’s requirements and to sufficiently inform agency decision-making in the context of the significant and growing risks climate change poses to the energy system. The comments describe and link to resources that ICRRL and its partners have published that can inform FERC’s development of guidance on climate impact analysis, which were also appended to the comments.

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