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01 Mar 2023 | OP ED Watch

Because governments have so little else do to, and are doing it so well, the American federal government is apparently planning to make evaluating carbon emissions central to every initiative it undertakes. According to the notice “Guidance: National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change Posted by the Council on Environmental Quality on Jan 9, 2023” posted on Regulations.gov, “The United States faces a profound climate crisis and there is little time left to avoid a dangerous – potentially catastrophic – climate trajectory.” It also says “Elevated concentrations of carbon dioxide will persist in the atmosphere for hundreds or thousands of years, so the earth will continue to warm in the coming decades.” So we’re tempted to comment that as resistance is futile we might as well party like it’s 500 ppm. But apparently there’s still just enough time to solicit comments, not that the agencies will pay any attention to them unless you happen to share their view that “The warmer it gets, the greater the risk for more severe changes to the climate and the earth’s system.” Did you think they were soliciting comments because they want to know what you think?

No. It’s not that kind of document. However it is this kind:

“Further, climate change raises environmental justice concerns because it will disproportionately and adversely affect human health and the environment in some communities, including communities of color, low-income communities, and Tribal Nations and Indigenous communities.”

To which we can only say where are the women and children in this all-encompassing cosmic lunge for social justice? Did you drop your Buzzword Bingo sheet into the rising oceans?

In case you’re wondering where these bureaucrats got their information, they reference another document from the bureaucrats at the EPA that starts:

“Climate change is happening. Global average temperature has increased about 1.8°F from 1901 to 2016.1 Changes of one or two degrees in the average temperature of the planet can cause potentially dangerous shifts in climate and weather. These real, observable changes are what we call climate change impacts because they are the visible ways that climate change is affecting the Earth. For example, many places have experienced changes in rainfall, resulting in more floods, droughts, or intense rain, as well as more frequent and severe heat waves.”

So never mind those deniers at the IPCC saying we haven’t seen such effects yet, and worrying that they might hit someday. We want the world on fire and we want it now. Or something, since it then says:

“Elevated concentrations of carbon dioxide will persist in the atmosphere for hundreds or thousands of years, so the earth will continue to warm in the coming decades. The warmer it gets, the greater the risk for more severe changes to the climate and the earth’s system.”

Uh, did somebody cut and paste here? Mind you that one continues:

“Although it’s difficult to predict the exact impacts of climate change, what’s clear is that the climate we are accustomed to is no longer a reliable guide for what to expect in the future.”

So it’s not here yet. But it is, in that everything is different or will be unless it’s not and cause and effect are suspended and the past is no guide to the future. (It also references another that starts “Greenhouse gases (GHGs) warm the Earth by absorbing energy and slowing the rate at which the energy escapes to space; they act like a blanket insulating the Earth” which is almost exactly what they don’t do. Where in the atmosphere is this “blanket” located, pray tell?)

So is it all clear yet? If not, read on. The CEQ item on Regulations.gov mandates that when agencies develop policies under NEPA, the National Environmental Protection Act, “where one or more climate effects could impair the operation of the proposed action, the agency should identify possible adaptation measures to enhance the action’s climate resilience.” So actions to respond to climate effects to make actions more resilient. Get right on that one, will you? Also:

“NEPA requires agencies to consider the reasonably foreseeable direct and indirect effects of their proposed actions and reasonable alternatives (as well as the no-action alternative).”

So basically you have to predict everything accurately, including how everything connects to everything else, and propose plans to adapt accordingly. Surely a reasonable requirement from a government that can’t predict the next train derailment, let alone the weather next week.

BTW Regulations.gov bills itself as “Your Voice in Federal Decision Making”. And here we thought your voice was heard in the ballot box or via your Congressperson. But bureaucracy is a world unto itself. Including that “This interim  GHG guidance, effective upon publication, builds upon and updates CEQ’s 2016 Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews (“2016 GHG Guidance”), highlighting best practices for analysis grounded in science and agency experience.” How can an interim document update a final one?

For those inclined to share your thoughts with them they pledge that “All comments received will be posted without change to https://www.regulations.gov, including any personal information provided.” Perhaps they have never read the comments section of a social media post. Have they never had to deal with obscenities, misspellings and conspiracy theories? And people posting phone numbers in the hope of a hot date? In the name of improved decision-making? Yuck.

Mind you the fact that you can only respond by first going to a portal and searching a docket, then slogging through confusing options before persuading a robot you aren’t one, or by snail-mail, or by something called a “fax,” but not by email suggests that they aren’t quite up on what’s going on out there or very keen on feedback (so far under 50 comments so lack of mission accomplished).

We wonder if they’d post something correcting their boilerplate “Rising GHG levels are causing corresponding increases in average global temperatures and in the frequency and severity of natural disasters including storms, flooding, and wildfires.” Or is it not the kind of voice they’re looking for in federal decision-making?

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