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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
94EDDIE OQUENDORECYCLE USED COOKIMG OIL FROM HOME LLC321 MIAN ST 304 NORWICH CTConsideration of Greenhouse GasesDear executive contact: This company is a new green recycling company which is in process of producing a recycling bottle to collect residential waste oil. The goal of the company is to coordinate the distribution of the collection bottle to residences within the country, collect the waste and then distribute to biodiesel recycling plants. clea energy production for the goverment. This company, however, is in need of relationships with companies such as yours in order to accomplish the company objectives. My name is Eddie Oquendo and I am the owner and founder. I am interested in scheduling a meeting with one of your representatives in order to discuss my business further and to explore possible business relationships with you in greater detail. Please feel free to contact me at eovirella@yahoo.com or visit my website http://homerecyclecookingoil.com.
95Mark 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.
96Michael JagoUSAF - NEPA analysisNiceville FloridaConsideration of Greenhouse GasesI find the 25,000t/y discussion a bit confusing as it is not to be used as a threashold. Would this indicate that a project that would produce 20,000t/y would be 80% of significant? Also the use of public lands for carbon sequestering is very depentant on the type and capicity of the land itself. Eastern forests, great plains grasslands, and western desert have very different carbon impacts and capaities. How is that to be addressed? I would recommend adding an exemption for small projects that require evaluatoin beyond CATEX but still have negligible impacts such as the construction of new (or replacement) structures that will be more efficient (LEED standards) than what they replace. The proposed rule indicates this is what is intended witout quantifying or outright stating it.
97Robert 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.
98Phillip 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.
99Gary C. FawverPennsylvania Department of TransportationHarrisburgPAConsideration of Greenhouse GasesComments are noted in the attachment.
100Elizabeth HabicMaryland State Highway AdministrationBaltimoreMarylandConsideration of Greenhouse GasesThank you for the the opportunity to comment on CEQ’s “Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse Gas Emissions." Maryland SHA's comments are intended to bring attention to areas in the guidance which may need further clarification or may be of concern due to the nature of NEPA analysis regarding transportation type projects. Emissions with a threshold of 25,000 metric tons/year is difficult to apply to transportation projects and should not be a requirement for mobile source analysis. Because transportation projects often redistribute existing traffic the analysis would be difficult to calculate the additional GHG emissions and would require analysis on a regional basis. If this threshold were included in the final guidance, would there be a list of exemptions as included for MSATs under 40 CFR 126.93 (b) (1) Table 2? Impacts would be difficult to assess without establishment of a baseline of reasonably foreseeable future climate conditions. Without a baseline, only a qualitative assessment of impacts to a specific resource could be completed. While using a qualitative or "global context" approach is suggested, and including a "direct link" to specific climatological changes, or the environmental impacts thereof to the particular project is discouraged, "the level of detail in the analysis will vary among affected resource values." The draft guidance seem to suggest being non-project specific on the one hand, and project specific on the other hand. Agreed, climate change should be a consideration in project analysis when located in areas considered vulnerable to specific effects of climate change within the project's lifetime. Because the impacts from climate change are predictions and can vary so widely by region, NEPA should be open to allow for differences in analysis. For example, Maryland has seen an increase in sea-level rise over the last 100 years but the rise is exacerbated by land subsidence which may not be the case in other low-lying areas in the US. As with variances in impacts by region, NEPA studies are conducted for such a wide variety of actions, there should not be requirements to address specific climate change impacts such as water resources. As GHG emissions are a global problem, there could be misleading information generated if project level analysis were attempted and analysis requirements may lead to lengthy discussions in documents without providing important information for decision-making. Other thoughts/questions are: The term "indirect" is not clearly defined as it relates to "direct and indirect" GHG emissions. How will NEPA guidance take GHG emissions analysis requirements into context with economic trends and growth? Can there be any further specifics as regards the statement "climate change impacts on humans will be compounded by an aging population and has the potential to accentuate the disparities already evident in the American health care systems as many of the expected health effects are likely to fall disproportionately on the poor, the elderly, the disabled, and the uninsured". The draft guidelines appear to be pointing generally toward potential EJ issues. Please clarify intent of this section in the guidance. Thank you for consideration of our comments.


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