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GHG / Climate Change

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Row numberNameAffiliationHome TownState or CountryType of CommentCommentAttachment
51Mary Lankford Sublette County, WyomingPinedaleWyomingConsideration of Greenhouse GasesSee Attachedhttp://www.whitehouse.gov/files/ceq/greenhouse_gases.txt
52Dan ReganInterstate Natural Gas Association of AmericaWashingtonDistrict of ColumbiaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/INGAA.pdf
53Tom TroxelIntermountain Forest AssociationRapid CitySouth DakotaConsideration of Greenhouse GasesSee Attachment.http://www.whitehouse.gov/files/ceq/intermountain_forest_association.doc
54Kathleen SgammaIndependent Petroleum Association of Mountain StatesDenverCOConsideration of Greenhouse GasesPlease accept the attached comments.http://www.whitehouse.gov/files/ceq/ipams_comments_to_ceq_on_nepa_analysis_of_climate_change.pdf
55Robert S. LynchIrrigation and Electrical Districts Association of ArizonaPhoenixArizonaConsideration of Greenhouse GasesSee attached.http://www.whitehouse.gov/files/ceq/irrigation_and_electrical_districts_association_of_arizona.doc
56GREGORY M. ADAMS Los Angeles County Sanitation DistrictsWhitterCaliforniaConsideration of Greenhouse GasesSee draft comment letter.http://www.whitehouse.gov/files/ceq/lacsd_comment_ltr_on_draft_nepa_ghg_guidance.pdf
57Alicia McDevitt, Assistant Secretary Massachusetts Executive Office of Energy and Environmental AffairsBostonMassachusettsConsideration of Greenhouse GasesPlease see the attached letter from Secretary Ian A. Bowles on behalf of the Massachusetts Executive Office of Energy and Environmental Affairs. http://www.whitehouse.gov/files/ceq/mepa_comments_to_ceq_on_draft_ghg_guidance_under_nepa.pdf
58Steve ColvinMinnesota Department of Natural ResourcesSt. PaulMinnesotaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/MNDNR.txt
59Dustin Van LiewNational Cattlemen's Beef Association & Public Lands CouncilWashington DCWashington DC Consideration of Greenhouse GasesNCBA & PLC comments on GHG and NEPAhttp://www.whitehouse.gov/files/ceq/ncba-plc_nepa_ghg_comments_0510_-_final.pdf
60Robert A. WymanLatham & WatkinsLos AngelesCAConsideration of Greenhouse GasesSee attachmenthttp://www.whitehouse.gov/files/ceq/ncc_comments_on_ceq_draft_nepa_ghg_guidance.pdf
61Wendy E . ThomasVirginia Secretary of TransportationRichmondVirginiaConsideration of Greenhouse GasesSee attached letter.http://www.whitehouse.gov/files/ceq/nepa_comments_ghg_5-24-10.pdf
62Matthew NocellaNational Hydropower AssociationWashingtonDCConsideration of Greenhouse GasesAttached.http://www.whitehouse.gov/files/ceq/nha_comments_on_nepa.pdf
63Ben BrandesNational Mining AssociationWashington District of ColumbiaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/NMA.pdf
64Mark ComptonNorthwest Mining AssociationSpokaneWashingtonConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/northwest_mining_association.pdf
65Carol E. WhitmanNational Rural Electric Cooperative AssociationArlingtonVirginiaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/NRECA.pdf
66Catherine LeslieNew York Department of TransportationAlbanyNew YorkConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/ny_dot.pdf
67Darlene WeaverOregon Department of TransportationSalemOregonConsideration of Greenhouse GasesSee attached PDF (3 pages)http://www.whitehouse.gov/files/ceq/odot_comments_on_ghg_and_cc_draft_ceq_guidance_may_2010.pdf
68Stephanie YoungThe Partnership ProjectWashington District of ColumbiaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/partnership_project_0.pdf
69Multiple Petitioners (14,000)private citizensAnywhereUSAConsideration of Greenhouse GasesSee attached.http://www.whitehouse.gov/files/ceq/petition_on_gcc.pdf
70Mike SmithQuestar Exploration and Production CompanyCheyenneWyomingConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/Questar_0.txt
71Craig JohnsonRio TintoSouth Jordan UtahConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/rio_tinto.txt
72Trip PollardSouthern Environmental Law CenterRichmondVirginiaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/SELC.pdf
73Heather LoweMaryland State Highway AdministrationBaltimore MarylandConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/sha_nepa_mit_and_monitoring_comments.xls
74Leslie Garrett AllenSouthern CompanyBirminghamAlabamaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/southern_company.pdf
75Deidre G. DuncanHunton & Williams LLPWashingtonDCConsideration of Greenhouse GasesSee attached letter.http://www.whitehouse.gov/files/ceq/spectra_comments_on_ceq_climate_change_guidance.pdf
76Ray D. HedrickSalt River ProjectPhoenix ArizonaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/SRP.pdf
77Dianna F. Noble, P.E.Texas Department of TransportationAustinTexasConsideration of Greenhouse GasesSee attachedhttp://www.whitehouse.gov/files/ceq/ted_boling_ltr_ghg.pdf
78Anna K. SchwabUniversity of North CarolinaChapel HillNorth CarolinaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/unc_csnhd.pdf
79Victor FlattUniversity of North CarolinaChapel HillNorth CarolinaConsideration of Greenhouse GasesSee Attachedhttp://www.whitehouse.gov/files/ceq/unc_school_of_law.doc
80Marc MillerUniversity of Arizona College of LawTucsonArizonaConsideration of Greenhouse GasesSee attached comments.http://www.whitehouse.gov/files/ceq/university_of_arizona.pdf
81Ross EisenbergUS Chamber of CommerceWashington District of ColumbiaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/uschamber_of_commerce.pdf
82Mary O'BrienGrand Canyon TrustCastle ValleyUtahConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/utah_forest_program_manager.doc
83Mary O'BrienGrand Canyon TrustCastle ValleyUtahConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/utah_forests.doc
84Hillary Brickey BrennanUtility Water Act GroupWashingtonDistrict of ColumbiaConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/UWAG.pdf
85Janice AdairWashington State Department of EcologyOlympiaWAConsideration of Greenhouse Gasesplease see attached document http://www.whitehouse.gov/files/ceq/washington_state_ceq_ghg_guidance_.pdf
86Holly PropstWestern Business RountableLakewoodColoradoConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/WBRT.pdf
87Erik Schlenker-GoodrichWestern Environmental Law CenterTaosNew MexicoConsideration of Greenhouse GasesPlease find attached comments from Western U.S.-based conversation groups.http://www.whitehouse.gov/files/ceq/WELC_CEQclimateguidancecomments_5.24.2010.pdf
88Gwen EklundWEST AssociatesAustinTXConsideration of Greenhouse GasesPlease see attached comments on behalf of WEST Associates. Thank you, Gwen Eklundhttp://www.whitehouse.gov/files/ceq/WEST%20Associates%20Comments%20on%20CEQ%20NEPA%20May%2024%2C%202010.pdf
89Robert K. HarrisWestern Resource AdvocatesBoulderColoradoConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/western_resource_advocates.pdf
90Mary LankfordSublette County, Wyoming Pinedale Wyoming Consideration of Greenhouse GasesSee Attached to accompany submitted comments. http://www.whitehouse.gov/files/ceq/white_house_ceq_comments.doc
91Cary e. BrusNerd Gas Company LLCCasperWyomingConsideration of Greenhouse GasesMay 24, 2010 White House Council on Environmental Quality NEPA Process Guidance SUBMITTED VIA WEB SITE: http://www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/submit?topic=Monitoring Environmental Mitigation Commitments Subject: Comments on NEPA Mitigation and Monitoring Guidance To Whom It May Concern: Nerd Gas Company, L.L.C. would like to submit comments supporting responsible development of new guidance governing Mitigation and Monitoring actions in the federal process for National Environmental Policy Act (NEPA) projects and actions. Nerd Gas Company, located in Casper, Wyoming, is dedicated to the efficient and responsible exploration and production of hydrocarbons in the northern Rocky Mountain region in order to provide energy and the associated tax base necessary for our communities, state and nation to remain financially strong and independent. We believe that the CEQ proposal to require mitigation is illegal, outside the boundary of law, and we do not support it. Further, the CEQ proposal would do more to slow an already sluggish NEPA process – the worst thing to do in the current economic climate. The Council does have a role to issue guidance; however, such guidance should stick to high level processes, not actions on the ground. Many agencies already use mitigation and monitoring, and those processes can always be improved – the basic process framework should be the only thing addressed by this guidance. While transparency in government is generally a positive thing, this could be taken to an extreme that is not realistically feasible for federal employees to implement. If this guidance were finalized as currently written, it would add significant workload to already overworked federal employees and stall all activity or interactions that the public has with the federal government. Especially in the current economy, government agencies should implement processes to make it easier to do things, not more difficult. The NEPA process is already very expensive, and this guidance would add to that expense. Under the current budget constraints, and considering the need for timeliness in resource management decisions on the ground, we would urge the Council to make the process easier for everyone, not more difficult to manage or work with. We have several more general concerns with the mitigation and monitoring guidance – particularly that the guidance goes far beyond the bounds of what NEPA was created to do. The NEPA itself is a procedural statute – it includes no mandates for action or non-action. Rather, NEPA’s goal is to analyze alternatives and identify potential environmental impacts associated with each alternative. The proposed guidance would significantly increase and expand the parameters of NEPA, and goes beyond the bounds of the legal jurisdiction of that law. If this guidance were to be implemented as written, it would lead to complete gridlock of any projects on federal land across the country. In the current economic climate, it would be irresponsible and unwise for the federal government to add bureaucratic impediments to projects that would create jobs and allow for continued economic development in rural and urban communities. Mitigation and monitoring, by themselves, are necessary and should be dealt with at the appropriate levels within each agency. This guidance, as written, provides an innumerable source of new points for litigation. If the guidance is finalized as currently written, we would be obligated to take up a legal challenge to the expansion of the mitigation and monitoring program beyond what is required in NEPA itself. In Robertson v. Methow Valley Citizens Council, the Supreme Court held that NEPA does not obligate agencies to require mitigation of impacts; rather, several court decisions have held that mitigation measures developed or recommended during the NEPA process need only be developed “to a reasonable degree.” Again, we would encourage the Council to develop basic guidance allowing for mitigation and monitoring plans within the NEPA process, without requiring such plans and creating additional bureaucratic roadblocks to activities on federal lands. Regarding specific goals, as written in the guidance, we have the following reaction: “Proposed mitigation should be considered throughout the NEPA process” Mitigation may be considered, and uses of best management practices or other measures should be strongly suggested. However, the NEPA process was designed to identify potential environmental impacts from activities on public land, not necessarily to pass judgment on any one alternative over another. Therefore, no contingencies should be mandated on the process which would restrict the ability of land managers on the ground to make their most informed decision to approve a FONSI or Decision Record. “mitigation measures…should be identified as binding commitments” This specific goal of the guidance overreaches the Act itself more than any other. Nowhere in NEPA is authority given for agencies to enact binding requirements before approval of activities on federal land. If monitoring after a project has been approved in a manager’s decision record or FONSI, an agency cannot legally retract that decision or change the terms of the decision after the fact. If mitigation is implemented, the federal government does not have the authority to enforce any changes after a decision has been made. “public participation and accountability should be supported through proactive disclosure of, and access to, agency mitigation monitoring reports and documents” Placing additional steps into the NEPA process by adding a public participation component to any mitigation measures defeats the purpose and efficiency of completing an EA versus an EIS. While we admire the goal of having more transparency in government, this would place an undue burden on federal employees. One of the challenges of NEPA as the process works today is that any environmental review and ongoing mitigation measures take an inordinate amount of time to complete – hence you have Members of Congress exempting specific projects in their districts from the NEPA process to bypass the gridlock that already exists. If this guidance is enacted as currently written, the gridlock that we see today would be considered a best-case scenario in a new world where no projects could be completed in any reasonable amount of time. One other issue that concerns us is the use of “outside resources” or experts by agency staff in the development of mitigation measures for any federal project. Any such experts should be true, neutral third parties with impartial and unbiased scientific credentials. If outside resources other than academic or scientific experts are used, consultations should also include adjacent landowners, local governments, and any other impacted entities in the discussion. We would be highly concerned with any one group having more influence or access in the process than another, and would caution the CEQ to ensure that any guidance ensures the use of impartial experts, such as university researchers. Thank you for allowing us to comment on this effort. Pease take these comments into consideration as you finalize the guidance on whether to expand Mitigation and Monitoring efforts in the NEPA process for all federal agencies. Nerd Gas Company looks forward to continuing to provide comment throughout this effort. Sincerely, Nerd Gas Company, L.L.C. By: Cary E. Brushttp://www.whitehouse.gov/files/ceq/white_house_council_eq_-_greenhouse_gases.pdf
92Jim MagagnaWyoming Stock Growers AssociationCheyenneWyomingConsideration of Greenhouse GasesSee Attached.http://www.whitehouse.gov/files/ceq/WSGA.doc
93Bruce PenderyWyoming Outdoor CouncilLanderWyomingConsideration of Greenhouse GasesSee attached.http://www.whitehouse.gov/files/ceq/wyoming_outdoor_council_comments_0.pdf
94Mark PrebilicUS CitizenPoolesville, MDUnited StatesConsideration of Greenhouse GasesI applaud your efforts at requiring further environmental study of Federal initiatives that will generate significant greenhouse gas emissions. I see this effort as a way to bring to the forefront the serious nature of Global Warming and I could see it further promoting the development of alternative means of power generation that are not as degrading to our environment.
95Robert P. O'NeillPrivate SectorPlymouth MeetingPAConsideration of Greenhouse GasesThe "science" used to classify CO2 as a pollutant is of course faulty, regardless of the EPA's decision to regulate CO2 Emmissions. The degree to which anthropogenic inputs of Carbon into the atmosphere affects global temperatures is also unknown. Studies and reports claiming that human inputs of carbon gases into the atmosphere cause temperature increases are based on faulty data and suspect science. As such, there should be no consideration given to the impact of Greenhouse gases under NEPA.
96Joy Keniston-LongrieSeattle Public UtilitiesSeattleWashingtonConsideration of Greenhouse GasesGreen House Gas Emissions: 1. Green House Gas & Decision-Making: NEPA and SEPA can play a critical role in decision-making associated with the role of green house gas emissions and climate change if it is incorporated early enough in both policy, programmatic and project decision-making processes which look at the entire life-cycle of a project. It is important that potential greenhouse gas emissions evaluated include the materials utilized for a project (construction & operating); construction impacts; and on-going operation and maintenance activities for the total life-cycle of a project. 2. Proposed 25,000 metric tons of CO2-e: This is another emerging environmental area that CEQ should consider as it thinks through an adaptive management approach with increased scientific information and monitoring of actual projects. Due to the fact that: climate change and green house gas is a critical issue; the time-horizon to adjust and have a positive environmental outcome is long; action is needed now; and we have to start somewhere -- 25,000 metric tons may be a reasonable threshold to consider provided that adaptive management is defined and appropriate adaptive management protocols can be established. 3. Federal Land & Resource Management Actions: Based on Seattle Public Utilities experience as a land-owner and resource manager, we encourage CEQ to extend the greenhouse gas emissions analysis to actions taken by and on federal land and resource management activities. CEQ should establish a stated goal for all federal land and resource management activities such as 50% sequestration improvement by 2020, and 80% improvement by 2100 -- to support sustainable harvest and old-growth diversification habitat in the forests and sustainable use in other resource extraction intense activities. SPU will forward to CEQ under separate cover suggestions to the seven (7) "Specific Questions for Public Review" in the near future for consideration and input. 4. Cumulative Effects: The ability to track and analysis cumulative effects is probably one of the most important and challenging parts of adaptive management associated with greenhouse gas emissions, yet one of the weakest areas of NEPA. Cumulative effects is technically difficult at the same time that it is a critical component to successful implementation of greenhouse gas emissions and decision-making. The current process is so decentralized, fragmented and inconsistent that there is no cost-effective method of providing meaningful/reliable information to provide decision-makers. The result is that decision-makers have difficulty understanding how the incremental decisions made project by project, program by program and policy by policy add up over a defined period of time and the potential environmental impacts. As part of the steps CEQ is considering to "Modernize & Reinvigorate NEPA" a paradigm shift in how cumulative effects are characterized and considered in decision-making needs to take place. SPU would be happy to work with CEQ to improve this process by providing a local/regional perspective to a national/global challenge. Climate Change: 1. Assessing climate change effects on proposed action: Many policies, programs and capital projects take years to plan, design and construct, and have a projected life of many decades, if not centuries. How potential scenarios of climate change and potential impacts on the proposed capital projects during the life-cycle of the project is evaluated is an important and relevant environmental impact question which is not traditionally addressed in NEPA, SEPA or traditional capital public works planning. These are important issues to address and SPU supports strengthening this aspect of NEPA/SEPA. 2. National Guidelines for Climate Change Range of Impacts: In order for meaningful analysis of climate change effects on a proposed action, it would be helpful to have national and regional guidelines to assist with that analysis. SPU is willing to actively participate in the development of guidelines based on our local/regional experience. 3. Adaptive Management: SPU strongly supports adaptive management as a critical tool for implementation of climate change. It would be helpful if CEQ developed and published proposed guidance on Adaptive Management. Seattle Public Utilities is interested in helping, and perhaps the National Science Foundation should also assist if they are not already participating with CEQ on this issue.
97Phillip FreemanNoneWashburnWisconsinConsideration of Greenhouse GasesMy comments are focused on guidance to land managing agencies regarding effects of proposals on GHG emissions. It is very important for the guidance to recognize the effects of "leakage" (borrowing from carbon offset terminology). Specifically, since timber harvest levels are driven by consumer demand, decisions about silvicultural practices on public lands will be offset by changes in harvest levels on other lands. Therefore, decisions related to sustained yield timber management on Federal lands will have minimal effects on total GHG emissions. Failing to keep this in mind could easily result in CEQ guidance that will lead analysts down a path of wasting resources on quantifying site-specific carbon flux values when the results actually add nothing of value to the decision making process. I applaud your efforts to take the issue of climate change seriously, but it is important that we focus on analysis that can make an actual difference in emissions. For Federal land managing agencies the relevant proposals are essentially limited to those that involve permanent conversion of forests to non-forest, that promote or tend to increase the practice of motorized recreational activities, or that would increase fossil fuel use associated with transport of timber or processed forest products.
98Jessica kayserGraduate StudentHainesAKConsideration of Greenhouse Gasesconsidering the obvious impacts of climate change on different regions in Alaska it is critical that Greenhouse Gases are considered in the NEPA process. There should be additional processes of the NEPA process that take into consideration the affects of climate change on the region of the proposed project and how the infrastructure planned will adapt to these affects.
99Andrew OrlemannUSDA Forest ServiceParowanUtahConsideration of Greenhouse GasesFrom a practitioners viewpoint, the CEQ should not require NEPA analysis to address the impact of a changing climate on a proposal; the CEQ should only require an assessment of the impact of a proposal on the changing climate. It is highly debatable that the NEPA process is an appropriate venue for analyzing and disclosing the potential impacts associated with global climate change on any proposed project. This gets the NEPA backwards. The NEPA requires that we address the effect of our project on the environment, not the effect of the environment on our project. The NEPA says that for major federal actions the responsible official should document “the environmental impact of the proposed action.” Period. The NEPA does not say that the responsible official should document the impact of the environment on the proposed action. This interpretation is supported by the federal courts. Judge Molloy recently addressed the issue of whether the Forest Service is required to document the effect of climate change on a project: “Plaintiffs misstate the analysis required by NEPA. NEPA does not [] require an analysis of how environmental factors such as climate change may impact an action. Instead, NEPA requires a “‘hard look’ at the impacts of [an] action [and] a reasonably thorough discussion of the significant aspects of the probable environmental consequences.” Hapner v. Tidwell, US District Court for the District of Montana, October 30, 2008, citations omitted. The question of potential climatic impacts on a proposal is properly addressed during the project planning and design phase. Logically, by the time an agency Interdisciplinary Team is analyzing the potential effects of a project on the environment under NEPA, the project design and planning phases have been completed. When the Forest Service is planning and designing a proposal, it naturally takes into account the social and environmental factors which may impact the proposal’s success. These factors are accounted for in designing a “reasonable” and “feasible” project. The Forest Service will not, for example, propose an action which is not economically feasible. Likewise, the agency will not propose an action which is not environmentally feasible. If a changing climate causes increased flooding in an area, the Forest Service will not propose building a campground in the flood. This is neither reasonable nor feasible. As a result, the proper place for the consideration of the effects of a changing climate on the success of a proposal is during project design, not during the assessment of environmental effects under NEPA. If the CEQ wants to address the question of how a changing climate affects a proposed federal action, it should do so outside the NEPA’s regulatory framework. The CEQ should not add complexity to an already complex process by requiring an analysis of something that is not included in the NEPA and that should be addressed by federal agencies prior to initiating the NEPA process.
100David LockTri-State Generation and Transmission AssociationDenverCOConsideration of Greenhouse GasesPlease see attached


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