CEQ guidance addresses biogenic emissions from land management

The Council on Environmental Quality, a division of the Executive Office of the President, has issued final guidance on considering greenhouse gas (GHG) emissions and climate change in National Environmental Policy Act reviews that addresses certain biogenic emissions.

The NEPA review process, implemented in 1970, essentially aims to ensure decisions made by federal agencies are environmentally sound. According to the CEQ, NEPA does not advocate for environmental preservation at all costs, but rather aims to balance environmental concerns with the social, economic and other requirements of president and future generations of Americans.

Regarding the new guidance, a notice posted to the Federal Register explains that many projects and programs proposed by, or requiring the approval of, federal agencies have the potential to emit or sequester GHGs and may be affected by climate change. As such, under NEPA, federal decision makers and the public should be informed about a proposal’s GHG emissions and climate change implications. “Such information can help a decision-maker make an informed choice between alternative actions that will result in different levels of GHG emissions or consider mitigation measures that reduce climate change impacts,” said the CEQ in the notice. The guidance applies to all type of proposed federal agency actions, including land and resource management actions, and provides agencies with a framework for consideration of GHG impacts and climate change to ensure efficient and transparent decision making.

Certain biogenic emissions are among the many issues discussed within the 34-page guidance document. Specifically, the guidance outlines special considerations for analysis of biogenic carbon dioxide sources and carbon stocks associated with land and resource management actions.

Under the heading of short- and long-term effects, the guidance notes biogenic GHG emissions and carbon stocks from some land or resource management activities, such as a prescribed burn of a forest, may result in short-term GHG emissions and loss of stored carbon. Long-term, however, a restored, healthy ecosystem may provide long-term carbon sequestration. “Therefore, the short- and long-term effects should be described in comparison to the no action alternative in the NEPA review,” states the CEQ in the guidance.

The guidance document also includes a dedicated section on special considerations for biogenic sources of carbon. “With regard to biogenic GHG emissions from land management actions—such as prescribed burning, timber stand improvements, fuel load reductions, scheduled harvesting, and livestock grazing—it is important to recognize that these land management actions involve GHG emissions and carbon sequestration that operate within the global carbon and nitrogen cycle,” explains the guidance, adding that it is possible that the net effect of ecosystem restoration actions resulting in short-term biogenic emissions may lead to long-term reductions of atmospheric GHG concentrations through increases in carbon stocks or reduced risks of future emissions. “In the land and resource management context, how a proposed action affects a net carbon sink or source will depend on multiple factors such as the climatic region, the distribution of carbon across carbon pools in the project area, and ongoing activities and trends,” states the CEQ in the guidance. “In addressing biogenic GHG emissions, resource management agencies should include a comparison of estimated net GHG emissions and carbon stock changes that are projected to occur with and without implementation of proposed land or resource management actions. This analysis should take into account the GHG emissions, carbon sequestration potential, and the changes in carbon stocks that are relevant to decision making in light of the proposed actions and timeframes under consideration.”

A full copy of the guidance can be downloaded from the CEQ website.