Fostering improved, clean transportation has the potential to benefit the country enormously, and advances key goals of the Biden Administration. The transportation sector is the largest source of greenhouse gas emissions in the United States, accounting for one-third of all emissions, and must be addressed for there to be any hope of meeting climate goals. Transportation also affects every American's day-to-day life, from how they participate in their communities to how they pursue economic opportunity and empowerment, representing a significant opportunity to promote equitable growth.
The Blueprint is the Administration's most fleshed out vision for pursuing these goals. The Blueprint outlines a comprehensive approach, addressing changes to every mode of transportation, and proposing to do so through virtually every policy lever available—a true "whole of government" approach. It is consistent with, and further advances, key themes in the President's climate policy enunciated from day one, and further reflected in his signature legislative accomplishments, the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA).
The Blueprint was a highlight of government speakers at the recent Government/Industry Conference for the auto industry, sponsored by the Society of Automotive Engineers: In a keynote, Gabe Klein, Executive Director of the newly formed DOE-DOT Joint Office of Energy & Transportation, called it the "most important policy document in a decade."
Below are some of the key features:
The continued prominence of liquid fuels in a transportation decarbonization plan is especially notable. There remains active debate, even within the agencies which authored the Blueprint as to whether the types of "sustainable" fuels being promoted have the full range of climate benefits they claim.
Whether the Blueprint's lofty ambitions will be met remains to be seen, but the document is an important outline of the federal agenda to come, at least for the remainder of Biden's presidency. The transportation sector is in the process of fundamental change, set to dramatically reduce where feasible uses of the internal combustion engine—the technology that served as its bedrock for over 100 years. This process will create exciting opportunities and difficult choices, and the Blueprint provides important insight into federal priorities that should be thoroughly understood when engaging policymakers going forward and when making investment decisions.
On January 6th, the White House Council of Environmental Quality ("CEQ") released a new Guidance on Consideration of Greenhouse Gas Emissions and Climate Change ("the Guidance") in permitting decisions, with significant implications for energy and infrastructure projects. Though this Guidance is effective as of the date of publication, it was issued on an interim basis and CEQ will consider comments until March 10th, after which it could be revised further.
CEQ's recommendations will influence the Biden Administration's analysis of greenhouse gas ("GHG") emissions in environmental reviews under the National Environmental Policy Act ("NEPA"), applying immediately to all newly proposed actions as well as some on-going NEPA reviews. While the Guidance is largely framed as a series of recommendations rather than requirements, it highlights best practices for environmental reviews that could help expedite project completions, improve agency decision making, and minimize litigation risks for developers.万博体育app手机登录归根结底,CEQ正努力确保机构和项目开发商充分关注气候影响,不无端延迟机构决策,特别是考虑到加速清洁能源基础设施是Biden爱慕气候议程的一个关键部分。
指南力求加深理解温室气体影响和替代物取舍,从而提高对联邦温室气体分析质量的期望。 项目开发商希望与联邦监管商密切合作,确保NEPA机构审查的充足性。万博体育app手机登录失败可能为项目反对者提供诉讼路径 。
Below万博体育app手机登录Encouraging Consistency in Agency Analysis of GHGs
CEQ's Guidance builds upon an earlier 2016 policy document, and is the latest in a series of efforts aimed at enhancing certainty in agency GHG analysis.[1] This Obama-era 2016 guidance was revoked and replaced by the Trump Administration,[2] and then ultimately reinstated by the Biden Administration in early 2021.[3] In the interim, court decisions have required some kind of analysis of project climate impacts under NEPA, without articulating clear generally applicable guidelines as to what level of review would be sufficient, thus resulting in uncertainty.[4]
CEQ is encouraging more certainty in addressing GHG consequences, while acknowledging that any such analysis must be conducted in a measured, proportional, yet thorough manner.CEQ实现这一点的主要方式是建议机构量化并联系相关温室气体影响
CEQ recommends agencies first quantify all reasonably foreseeable GHG emissions and reductions of a proposed action, any reasonable alternatives, and a no action alternative. In doing so, CEQ recognizes the unique nature of the climate emissions challenge, where the effects arise from a wide range of emissions activities. It thus notes, "NEPA requires more than a statement that emissions from a proposed Federal action or its alternatives represent only a small fraction of global or domestic emissions."[5] In other words, an agency is not absolved from analyzing GHG emissions because no single agency action has the ability to mitigate climate change on its own. Instead, an agency must recognize that adequate reforms will occur incrementally, and therefore analyze the emissions impacts of significant federal actions that contribute to, or remediate, climate impacts.[6] To do so, CEQ directs agencies to use tools that are commonly deployed by the private sector and government to quantify emissions.[7]
Using these tools, emissions increases and reductions should be quantified individually by constituent greenhouse gases, as well as aggregated in terms of total carbon dioxide equivalency. Additionally, where feasible, agencies are encouraged to represent the proposed action's annual emissions or reductions, especially when those emissions might vary over the life of the project.[8]
CEQ further instructs that agencies evaluate direct, indirect, and cumulative emissions as part of their environmental review. Among other things, CEQ notes that quantifying direct and indirect emissions "is generally essential to reasoned decision making."[9] Cumulative emissions are critical to consider given the nature of the climate problem, where detrimental effects flow from the accumulation of historic GHGs. Consideration of cumulative effects can be accomplished by summarizing and citing to the relevant scientific literature, as well as monetizing and contextualizing emissions as noted in the following section.[10]
Analyzing direct, indirect, and cumulative emissions is likely to be one of the most challenging aspects of CEQ's guidance to implement, and similar recommendations have already been the source of some controversy. For instance, in February 2022, the Federal Energy Regulatory Commission (FERC) issued a policy statement stating that for gas pipeline approvals FERC would review "GHG emissions that are reasonably foreseeable" including those resulting from upstream impacts—such as those tied to construction and operation of the project—and downstream impacts—such as emissions resulting from the combustion of transported gas.[11] Barely a month later, FERC re-designated this policy statement as a draft and invited additional comments after it garnered significant industry and political criticism.
CEQ attempts to tamp down such controversy by making clear that any analysis of GHGs should be bounded by principles of proportionality. They caution against "an in-depth analysis of emissions regardless of the insignificance of the quantity of GHG emissions that the proposed action would cause."[12] For example, "the relative minor and short-term GHG emissions associated with construction of certain renewable energy projects, such as utility-scale solar and offshore wind, should not warrant a detailed analysis of lifetime GHG emissions."[13] In order to further enhance efficiency and avoid duplicative efforts, CEQ expects that agencies will rely on and incorporate scientific and technical information on impacts from other, more expert, agencies, as well as international organizations and academic literature.[14]
Agencies should contextualize GHGs associated with a project after quantifying them. This can include monetizing climate damages using the "best available estimates" of the social cost of GHG ("SC-GHG") and placing emissions in the context of relevant climate goals and commitments.
The best available SC-GHG figure is currently in flux. Two years ago, the Biden Administration reconstituted an Interagency Working Group (IWG) on the SC-GHG, which issued an interim estimate of the SC-GHG in the spring of 2021. As detailed in a prior blog post, that estimate has been the subject of litigation and the IWG has yet to issue a final SC-GHG. More recently, EPA issued a regulatory document in the fall of 2022, which previewed a much higher SC-GHG than contemplated in the IWG's interim estimate.[15]
CEQ nonetheless notes that "in most circumstances" agencies should use the SC-GHG to analyze a proposed action and its alternatives. In doing so, the SC-GHG will empower agencies to make clearer comparisons of the GHG impacts of each action.[16] Monetizing emissions is particularly useful if: (a) the NEPA review monetizes other costs and benefits from the proposed action!替代物在不同时间或温室气体排放类型上有差异and (c) the significance of the climate impacts are hard to assess or not readily apparent without monetization.[17] Any such SC-GHG should be global in nature and utilize a discount rate that accurately reflects the harms climate change inflicts on future generations.[18]
Despite encouraging the monetization of GHG impacts, CEQ clearly states that "NEPA does not require a cost-benefit analysis where all monetized benefits and costs are directly compared." Utilizing SC-GHG to estimate the societal cost of GHG emissions does not create a requirement to do so.[19] However, if an agency considers a formal cost-benefit analysis appropriate, it is not prohibited from including or appending this analysis to its NEPA documents.
For any actions "with relatively large GHG emissions or reductions" or that "perpetuate reliance on GHG-emitting energy sources"—such as fossil fuels—agencies should explain how the proposed action and its alternatives would meet or detract from broader climate goals and commitments, such as federal or state goals or international agreements.[20] For example, agencies could discuss how the actions align with the U.S.机构应考虑使用更多语法或无障碍方法描述温室气体排放量,其中一些例子可包括使用“familiar度量法,例如家用每年排放量、公路上一定数车或加仑燃烧汽油平均量值”。 CEQ is also using this Guidance to encourage agencies to take actions that lower GHG emissions by building such considerations into the process. This underlines CEQ's desire to align government decision making with the Biden Administration's net-zero ambitions. Embedded in this approach is the hope that a more complete consideration of GHG impacts will lead to more climate-positive decision-making, even though NEPA does not require agencies to opt for the most environmentally friendly alternative.[22] CEQ provides advice on how to consider reasonable alternatives and mitigation measures that might address short- and long-term climate change effects, with the aim of promoting emission mitigations.[23] CEQ notes that agencies should also acknowledge the impacts of climate change on the proposed action (not just the impact of the proposed action on the climate) and embed considerations of climate adaptation and resilience into the formulation of the proposed action and alternatives.[24] CEQ also recommends evaluating reasonable alternatives that have lower GHG emissions, including technically and economically feasible clean energy alternatives to proposed fossil-fuel projects.[25] CEQ notes how "[s]ome proposed actions, such as those increasing the supply of certain energy resources like oil, natural gas, or renewable energy generation, may result in changes to the resulting energy mix as energy resources substitute for one another on the domestic or global energy market." CEQ encourages agencies to conduct a "substitution analysis" to understand how any energy project proposals will affect the resulting energy mix and GHG emissions. When doing this analysis, agencies should not assume that if any project does not go forward it will be replaced by one that generates identical emissions, such that net emissions relative to a baseline are zero.[26] Instead, agencies should conduct modeling that "accurately account[s] for reasonable and available energy substitute resources, including renewable energy."[27] By encouraging the consideration of renewable energy alternatives to fossil fuel infrastructure early in the NEPA process, CEQ is pushing agencies to prioritize permitting cleaner forms of energy, consistent with the Administration's broader climate policy goals. CEQ鼓励前方社区参赛,重点是考虑环境公义对温室气体排放的影响万博体育app手机登录One of the most effective ways to accomplish this, according to CEQ, is to leverage early planning processes to integrate GHG emissions and climate change considerations into the identification of alternatives to the proposed action, as well as any reasonable mitigation efforts. CEQ recommends that agencies use the scoping process to identify potentially affected communities and provide early notice of opportunities for public engagement, which is especially important "for communities of color and low-income communities, including those who have suffered disproportionate public health or environmental harms and those who are at increased risk for climate change-related harms."[28] Community engagement should begin in the scoping process and should recognize any unique climate-related risks and concerns posed by the proposed action. For example, CEQ discusses how "chemical facilities located near the coastline could have increased risk of spills or leaks due to sea level rise or increased storm surges, putting local communities and environmental resources at greater risk."[29] In these types of scenarios, agencies should meaningfully engage with affected communities in designing the action and selecting alternatives, "including alternatives that can reduce disproportionate effects on such communities."[30] Such early project engagement, before the contours of a project are fully fixed, can assist in improving project outcomes and building greater community-level support for a project. We will continue monitoring developments pertinent to NEPA reviews of energy and infrastructure projects in the coming months, including CEQ's final guidance on GHG analysis expected in March, and other efforts by the Biden Administration and Congress to reform federal permitting processes. [1] CEQ, 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, 81 FR 51866 (Aug.万博体育app手机登录2016年4月5日CEQ撤销2016年最终指南。CEQ撤销联邦各部门和机构在国家环境政策法评审中审议温室气体排放和气候变化影响最终指南,III.Up-Front社区参与环境公义
[7] Guidance at 1201-1202. CEQ keeps a list of these tools on their website. See CEQ, GHG Tools and Resources, https://ceq.doe.gov/guidance/ghg-tools-and-resources.html.
[8] Id. at 1201.
[9] Id. at 1205.
[10] Id. at 1206.
[11] FERC, Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews, Docket No.万博体育app手机登录PL21-3-000, February 18, 2022.
[12] Guidance at 1201.
[13] Id.
[14] For instance, CEQ notes that "agencies may summarize and incorporate by reference the relevant chapters of the most recent national climate assessments or reports from the USGCRP and the IPCC" and encourages them to "engage other agencies and stakeholders with knowledge of related actions to participate in the scoping process to identify relevant GHG and adaptation analyses from other actions or programmatic NEPA documents." Guidance at 1208, 1210.
[15] Specifically, the February 2021 IWG estimates places the social cost of carbon at $51/ton, while the EPA in the fall of 2022 estimated the social cost of carbon at $190/ton. This larger estimate was derived in part by using lower discount rates.万博体育app手机登录See Supplementary Material for the Regulatory Impact Analysis for the Supplemental Proposed Rulemaking, "Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review," EPA External Review Draft of Report on the Social Cost of Greenhouse Gases: Estimates Incorporating Recent Scientific Advances, EPA-HQ-OAR-2021-0317 (September 2022).
[16] Guidance at 1202.
[17] Id.
[18] CEQ further notes that in utilizing a SC-GHG, agencies should keep in mind that currently available estimates "may be conservative underestimates because various damage categories (like ocean acidification) are not currently included." Id. at 1203.
[19] Id. at 1211.
[20] Id.
[21] Id.
[22] CEQ itself recognizes that "[n]either NEPA, the CEQ Regulations, or this guidance require the decision maker to select the alternative with the lowest net GHG emissions or climate costs or the greatest net climate benefits." Id. at 1204.
[23] Id. at 1203.
[24] Id. at 1208-1209.
[25] Id.1205 id>#em>
COP21NDC汇总后将保持世界轨迹以避免
worst气候变化影响,并每5年审查一次enview
周期作用鼠标,迫使每个国家带更多'br>雄心勃勃NCDs返回COP2020年因Covid而错过了COP26,格拉斯哥市去年COP26成为第一个五年审查点,评估通过
Paris协议后排减进度Glasgow大会因美国之故也很重要环球气候问题重新投入世界舞台, 由
政府间气候变化问题专门委员会发布的权威科学评估, 列出了smission轨迹日益可怕的冲击,清楚地表明这是世界降低排放以避免灾难性全球变暖目标的决定性十年。
UNFCCC评估说,各国在实现1.5度/br/celius目标方面没有取得足够的进展,并请求所有成员国返回COP27并改进目标COP27的Br>焦点因此放在前协议的“执行”上-由Br>会议标题Captement of“Togates for 实现”-不期望主要新Climate
变换文本会商谈近195国努力使用COP27来点火,但只有29个有改进NDCsssss.s/p>
squatedUnited United Nations/CEP27上的国家代表团外,还有近2千个官方观察组织-共约33 500名代表。 ibr>At开源开源开源开源开源开源开源开源开源开源并解决深度公平问题, 由谁来承担气候干扰和经济发展收益的冲击和负负在今年
ss观察欧洲和中国异常干旱时,承认这种不平等和附属于解决的发展中世界的
意义,除埃及作为
主机的作用外,COP27被计为“AfricanCOP”。
历史学上,全球应对气候变化可大致归为
或减排或改适应(准备未来变换
气候变换-例如加固海墙或改善对关键
国家基础设施的保护)。COP添加了另一个官方类别-“损耗和损耗”-它“br”处理气候变化影响问题,侧重于当前气候变化经济不良效应,以及一国无法通过恢复能力努力恢复
的问题。
然而,关键细节说明基金将如何运作,包括支付者、数额和操作方式,留待未来会谈解决这一点很重要,因为它可能`Br>政治挑战美国请求国会为损耗和损耗基金追加气候拨款, 并可能出现挑战性问题,并面临创纪录通胀和由
俄罗斯入侵乌克兰引发的大规模生活成本危机有关其他Br>key发射者-最突出的是中国-为这样一个基金提供捐款的作用问题仍然有待解答。
虽然发展中国家实现了建立损耗基金的长期目标,但
COP27未能实现迫使国家改善NDCs的目标The negotiations also
failed to secure an agreement to start a phase-out of all fossil fuels—language which at one
point had seemed to have made its way into the text, only to be withdrawn and replaced by the
Glasgow language of "phasing down" coal and "phasing out inefficient fossil fuel subsidies" after
objections from Saudi Arabia, Iran, and Russia.
Although an attempt to remove the 1.5 degree Celsius goal from the Declaration in favor of the
Paris Agreement's upper limit of 2 degrees failed, there was no mention of the requirement for
global emissions to peak by 2025, which scientists see as critical if the world is to meet the 1.5
degree Celsius target.减少排放焦点似乎因埃及增加低排放能源呼声
最后插入而削弱(俄罗斯入侵
Ukrain 和随后对俄罗斯油气公司的制裁触发非俄毒气的
点头)。
EU和UK表示失望,因为最终结果没有改善COP26上所作的
减排承诺委副会长表示, 国家有“下降短路 ” 补充道 : “我们应该多做多做多做多做多.我们Br失望我们没有实现这一点。 ”英国的 Alok
Sharma-CEP26主席表示,这一失望得到响应,他注意到省略逐步停用化石
燃料的承诺和任何语言都要求到2025年排放量封顶增强科学理解天然气生产中甲烷泄漏对
短期气候的影响以及比纯可再生能源游戏高排放轨迹概念加深了关于天然气过渡作用的辩论和争议Sharma总结说'br','我在Glasgow表示脉冲为1.5度微弱可惜它仍然保留在生命'br>支持上's/p>
除创建新的损耗基金外,CP27
中的其他亮点包括:
来自COP27的另一个亮点是多场边事件的广泛讨论,包括深入评估
对粮食和农业的影响和各种机会。
COP27还反映企业和民间社会作用在
COP进程的持续制度化COPs不再是单纯的联合国谈判,而只是定期
全球会议的一部分,由关注并受全球气候挑战影响者组成squmel>br>Sheik继续提升全球气候问题,并集中媒体和公关关注这一挑战-埃及有3000多媒体br>代表反映这一点。
归根结底,美国重新参战上个年度气候变化问题论坛由拜登总统(内阁秘书大全)和SqlmelSheik国会代表团组成,以突出美国投资解决Climate
change-历史记录(Investment
Rectection或IRA),帮助帮助美国运行自己的
NDC承诺并突出清洁能源和先进技术经济
契机。
微弱最后文本引导多位推理家得出结论说,将气候变化限制为1.5摄氏度可能不再有
现实性:鉴于今年干旱和洪涝对世界多处造成的损害,这些损害已经影响到
世界多处,仅摄氏1.1摄氏度,这是一个暗淡的未来。
其他评论家现在公开质疑COP
进程的可行性和实用性,它需要全体一致的所有决策But, since COP is the best we have
by way of a global system for managing climate change, it is a process that will have to be
made to work.
One other important lesson which should be taken away from the heated debate over differing
priorities at COP27 is the difficulty in neatly categorizing and separating "implementation" from
the issues of emissions reduction, global ambition, equity, integrity, and transparency that
underlie a solution to addressing climate change.
In terms of what we should expect from next year's COP28, there will be a focus on how to
operationalize the loss and damage fund, as well as a continued focus on the Global Goal on
Adaptation, the New Collective Quantified Goal on climate finance, and perhaps most important
for continued mitigation, the first Global Stocktake assessing progress on the NDCs of individual
countries and the on-going role of private sector emissions reduction commitments.
But achieving these tangible outcomes will require a sustained effort to rebuild trust and
confidence between the Global North and Global South.
通缩法(IRA)将大步限制并减少甲烷污染甲烷证明是气候问题的重要部分ips/unep.org/news-andssories/story/are-raistriew-climate-heres-show-redues-thes#:~Text=me%20is%20By implementing a Methane Emissions Reduction Program, the IRA takes a significant step towards reducing methane-related warming. This program implements a carrot-and-stick regulatory regime, whereby the Environmental Protection Agency (EPA) rewards methane reduction efforts with financial assistance, and penalizes excess methane waste with a set fee.
The IRA is the latest in a series of efforts by the United States to reduce methane emissions from the petroleum and natural gas sectors. Since taking office, the Biden Administration has recognized the challenges posed by methane emissions and prioritized cutting their emissions. In advance of the 2021 UN Climate Change Conference in Glasgow (COP 26), the United States and the European Union jointly launched the Global Methane Pledge, which asked countries to band together and commit to a collective goal of reducing global methane emissions at least 30% from 2020 levels by 2030. As of this summer, the State Department has announced that 120 countries have joined the pledge. In November of 2021, the Biden Administration further announced a series of regulatory actions to tackle methane emissions, from the oil and gas sector, landfills, abandoned coal mines, and agriculture.
The Methane Emissions Reduction Program complements each of these efforts and is the next significant step in the country's attempt to tackle methane-related warming. It would reduce methane emissions through two key mechanisms. IRA § 60113.First, it would provide $1.5 billion for EPA to support emissions monitoring and methane reduction efforts in petroleum and natural gas systems, through grants, rebates, contracts, loans and other forms of financial support. Id. These funds are directed at permanently shutting in and plugging wells on non-federal lands, to improving and deploying equipment that reduces methane emissions, and to supporting innovation in reducing methane emissions. Id.
Second, these incentives are coupled with a methane waste emissions fee applied to petroleum and natural gas systems emitting more than 25,000 metric tons of carbon dioxide equivalent gas. The fee will be calculated by multiplying the metric tons of methane emissions exceeding waste emissions thresholds by: (a) $900 for emissions in 2024!2025年排放1200元and (c) $1,500 for emissions in 2026 and each year thereafter. Id. Fees will only be imposed on emissions above a certain waste emissions threshold, which vary by industry segment and represent the leakage rate from well-designed and maintained systems in that segment, in turn providing an incentive for oil and gas systems to reduce methane leakage.
The Methane Emissions Reduction Program further promotes EPA's regulatory authority under the Clean Air Act, by exempting from the payment requirement any facilities that are in compliance with methane emissions requirements established for new and existing sources, so long as standards and plans have been approved and are in effect in all States and compliance with the requirements imposed by those standards and plans will result in equivalent or greater emissions reductions than can be achieved by EPA's November 2021 proposed rule to reduce methane in the oil and natural gas industry. This is a powerful floor!EPAss/www.epa.gov/system/files/documents/2021-11/2021-oil-and-gas-subject.-overview-fact-she..大于2019年全美释放的二氧化碳量passenger cars and commercial aircraft combined." By imposing a tax on emitters that are lagging behind and providing an exemption once all States are enforcing requirements that would achieve equivalent or greater reductions, the IRA's Methane Emissions Reduction Program creates strong incentives for both States and industry to adopt and comply with strong methane emissions standards.
As noted in another blog post, the Rhodium Group has estimated the IRA, if enacted, would cut domestic greenhouse emissions 44% from 2005 levels. In an earlier study of the emissions reductions associated with a prior iteration of the IRA, Rhodium described the methane emissions fee as one of six "big-ticket items that stand out" for its impact on reducing emissions. That the Methane Emissions Reduction Program is just one of many, game-changing provisions in the IRA underscores the potential impact of this bill for the energy sector and for achieving our nation's climate objectives.
This package presents the opportunity for Congress to finish legislating President Biden's Build Back Better agenda, completing the story detailed in our series The ABCs of the AJP. As we left the saga last summer, we noted that the effort to enact that agenda was Not Broken, Simply Unfinished. Today we are updating that series to detail the following energy related elements of the IRA:
As President Biden noted yesterday, "Sometimes seem like nothing gets done in Washington ...但政府工作可能缓慢和沮丧,有时甚至令人厌烦。 之后拒绝放弃支付的人辛勤工作时日月数计算。历史成真。生活变换 。 至此,这些情感可能还为时过早!Arizona-Has/news/2022/07/28/dmocrats-climate-xacco-Service-Bill-reces-00048459能源和气候政策,随着法案跨过立法过程最后阶段,我们将继续更新和补充覆盖量。
As the United Nations Climate Change Conference of the Parties ("COP") in Glasgow has drawn to a close, with seemingly mixed messages and a somewhat ambiguous conclusion, it is worth reflecting on the overall trajectory of the climate issue, societal expectations, and the accomplishments that — with time — Glasgow is likely to represent. COP26 highlighted the fragility of the planet, as well as the fragility of the global consensus-based United Nations approach to protecting it. It highlighted the sweep of global climate-induced challenges and the scale of transformation needed to address them. With rising temperatures has come a rising global focus on climate and a far greater set of emerging societal expectations for meaningful responses by government and the private sector. Despite the risk that the global agreement forged in Glasgow is seen by climate activists as all talk and no action — what they referred to as "blah, blah, blah" — I believe that a number of features will endure as important accomplishments.
Representatives from 197 nations, businesses, hundreds of civil society organizations, scientists, educators, media, and climate activists — you name it — all converged on Glasgow to shine a global spotlight on the climate crisis. The Conference had some 40,000 registered participants. With just a few thousand of those involved in the negotiations themselves, the rest converged around elevating climate understanding, climate solutions, and climate action. And still tens of thousands of others converged to protest and lend their voices to the climate debate.期望因Covid-19延迟一年以及美国返回巴黎气候进程而提高但这些期望都集中在依赖实现每一项结果一致性的联合国谈判进程上 。
尽管Covid云下集合和大批与会者所构成挑战,但缔约方会议在某些方面组织得比以往更好。它不再完全是一个国际谈判,而更多地是一个通信机制,以凝聚世界对雄心气候行动需求的看法United Nations进程启动全球领导人峰会,有120位国家元首参加It featured inspiring statements from governmental and societal leaders, such as Sir David Attenborough. The Summit then flowed into the overall COP, which had a thematic organization for each day of the conference, by which it highlighted actions or the sweep and scale of climate impacts in a more coherent fashion than ever before — spanning from energy, finance, transport, cities and the built environment, science and innovation, nature, gender, youth, and adaptation to and loss and damage from climate change. And the overall gathering encapsulated a heightened global focus on climate as a defining generational issue in a way that has never happened before.
The World Rallied Around the Urgency Shown By the Evolving Climate Science
The defining element of the Glasgow considerations was the acceptance of a far sharper sense of climate science findings around the scale and urgency of emissions reductions needed to stabilize the earth's climate and prevent catastrophic consequences. Every aspect of the discussions was judged by the context the new climate science shows.
Leading up to the COP, the UN's authoritative science body, the Intergovernmental Panel on Climate Change ("IPCC"), had issued two reports — one in 2018 focused on the imperative of holding global average temperature rise to 1.5 degrees Centigrade, and one in the Summer of 2021 highlighting the "overwhelming" evidence of climate change. The reports showed that a rise in global temperature to 2 degrees would lead to catastrophic results in both the frequency and severity of climate-induced events and global changes. The reports found the science of human-induced impacts "unequivocal" and noted that global temperatures had already risen by 1.1 degrees over pre-industrial levels — demonstrating how limited the remaining carbon budget is — and that climate adverse effects were widespread, rapid, and intensifying.The report further found that urgent action is needed to cut emissions by 45% by 2030 and achieve net zero emissions by 2050 in order to maintain a sustainable trajectory.
The IPCC findings were characterized by UN Secretary General António Guterres as a "code red for humanity." They became the touchstone for judging the adequacy of country pledges and private sector net zero commitments. In addition to the scale of the emissions reductions, the need for an accelerated pace of change also became far clearer and a widely accepted expectation. The notion that we are now in a "decisive decade" to get on the right emissions trajectory was embraced by the COP process. Going into the COP, various assessments, such as from the International Energy Agency, showed that existing country emissions reduction commitments would lead to a global temperature rise of 2.8 degrees by the end of the century. Those pledges covered less than 20 per cent of the gap in emissions reductions needed to be closed by 2030 to keep a 1.5 degree path within reach. According to a number of projections, the plethora of new commitments announced at the COP would, if delivered in full, lower the rise to somewhere between 1.8 and 1.9 degrees. The UN noted that the actual nationally determined contributions ("NDCs") submitted by participating nations would result in an unsustainable global temperature rise of 2.4 degrees.
At the end of the day, the overall agreement reached by 197 countries — including new emissions reductions announcements, the move to more regular revision of national commitments, transparency requirements around that process, and the development of rules for the global carbon markets — at bottom kept alive the possibility of limiting global temperature rise to 1.5 degrees by the end of the century and essentially transformed that temperature target into the new object of the UN process.虽然1.8度和1.5度之间的差值似乎不大,但实际上它代表着减轻气候变化最大破坏性影响的实质性差值。 广泛报道的争议涉及是否逐步停用煤炭和化石燃料补贴,发展中国家是否有足够的气候资金,以及是否向受影响国家提供补偿“损耗和损害”抑制了对协议的热度。 尽管如此,正如缔约方会议主席Alok Sharma得出的结论, “我们现在可以可信地说我们已经保住1.5度。But, its pulse is weak and it will only survive if we keep our promises and translate commitments into rapid action."
Paired with these science targets was a far more prominent voice given to the moral underpinnings to the proceedings that focused on the inequity created because the most vulnerable nations to climate impacts are those who have contributed least to the emissions causing such impacts, and a palpable sense of obligation to future generations. The IPCC report drove home the concept that the COP process is not some future exercise with distant impacts, but that the delegates were poised to address an urgent crisis of the here and now.
The Paris Climate Framework Survived the Absence, and Accommodated the Return, of the United States as an Active Participant
The nations of the world remained committed to the UN Climate Framework Convention's goal of "the stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system" even in the absence of U.S.巴黎气候协议自下而上承诺框架由每个国家根据自身环境确定,体现了应对这一全球挑战的共同全球承诺,没有美国则保持稳定和适切性participation, and the reaffirmation of that framework may be one of Glasgow's greatest accomplishments.
The Paris balance had achieved a "bottom-up" system of emissions reduction commitments that flexibly accommodates the circumstances of individual countries, yet one that does not allow so much flexibility that there is no realistic hope of actually bettering the climate situation by addressing emissions mitigation, adaptation to the already locked-in effects of climate change, and assistance for climate-impacted developing nations. Paris provided a solution and a directional sense of its goals, even as it admitted that its trajectory may need to grow more stringent over time, informed by meaningful science. Glasgow refined that process with a commitment by the parties to revisit their NDCs in one year rather than five and with enhanced transparency around individual country goals and their implementation. This process preserves the possibility that the collective emissions reduction actions are calibrated to avoid the worst climatic impacts.
The durability of the Paris structure was aided, to be sure, by the promise of new technology, which could allow for countries to enhance their emission reduction commitments through cost effective wind, solar, energy efficiency, and electric vehicle technologies — technologies that were still only on the verge in Paris — making a clean energy transformation that is consistent with the Paris climate goals today seem like an attainable objective.
When the United States did return to the negotiating table, it brought with it an ambitious NDC — pledging to achieve a 50-52 percent reduction from 2005 levels in economy-wide net greenhouse gas pollution by 2030, to achieve 100 percent carbon pollution-free electricity by 2035, and net zero emissions no later than 2050. It also brought a bevy of other actions to instill more confidence in its commitment.This included leadership in assembling a global methane reduction coalition by which more than 100 countries agreed to cut emissions to tackle this highly potent short-acting greenhouse gas by 2030, a "first movers" technology coalition, as well as a series of whole-of-government financial and regulatory initiatives.
While the Biden Administration would have liked to have had its actions backed up by climate legislation, particularly power plant incentives and a range of clean energy tax credits in the reconciliation bill, it made a strong case nonetheless about the comprehensive approach it is taking to prioritizing climate outcomes across the government, whether that be in the financial sector, energy, or transportation. And the United States demonstrated ambition in its diplomacy, reaching a surprise commitment with China to work collaboratively across a range of areas to keep alive the prospects for achieving 1.5 degrees. President Biden's address to the COP was complemented by a widely praised speech by former President Obama speaking directly to youth climate activists who had taken to the streets during the COP, as well as by Congressional leadership.
The Global Focus on the Climate Crisis Puts a New Spotlight on the Importance of Business Solutions and the Business Opportunities Around Climate — Subject to Ever Greater and More Intensive Scrutiny
The first week of the COP brought a breathtaking series of collaborative public and private sector announcements to achieve carbon emissions reductions. In many ways, these commitments seem almost as significant in accomplishing a clean energy transformation as the text of the UN agreement itself.
In addition to the methane pledge, leaders from over 120 countries, representing about 90 percent of the world's forests, pledged to halt and reverse deforestation by 2030. Hundreds of financial firms, operating through the Glasgow Financial Alliance for Net Zero (GFANZ), committed over $130 trillion of private capital — representing 40 percent of global financial assets — to transforming the economy for net zero.Various combinations of development organizations and private sector capabilities identified a range of opportunities they will pursue for investments in particular developing nation economies, such as in efforts to stem coal use in South Africa. Nearly 30 national governments, joined by cities, states, major automotive manufacturers, fleet owners, and investors, signed the Glasgow Declaration on Zero-Emission Cars and Vans to end the sale of internal combustion engines by 2035 in leading markets, and by 2040 worldwide. Other transportation commitments touched on heavy duty vehicle electrification, green shipping, and enhancing the deployment of sustainable aviation fuels.
Glasgow in many ways represents a shift in focus from a governmental initiative to a recognition that the scale and pace of the energy and societal transformation and response demanded by climate change necessarily will require swift and credible action by the private sector as well. As one Chief Executive Officer put it, the concept of a "climate-advantaged" company has taken hold, where sustainability has been transformed from a "nice to have" effort being done on the side, to a vital consideration at the center of business strategy, and where such companies can benefit from a substantial value premium. As one of the UN's High Level Climate Champions put it: "Net zero has gone from extreme to mainstream."
Of course, with the proliferation of net zero pledges comes an increasing level of skepticism about the credibility of those commitments and the ability to deliver on them in the long run. In the ramp up to the COP, the IPCC focus on the more stringent and nearer term emissions reductions meant that the Science Based Targets Initiative formally revised its goals for net zero corporate commitments to align with the new 1.5 degree IPCC target and issued a new standard for evaluating company emission reduction offerings. Along these same lines, the so-called "Under 2 Coalition," representing commitments by some 60 percent of world's economy, is recasting itself as the "Net Zero Coalition."
Likewise, the UN Secretary General, at the Opening to the World Leaders Summit portion of the COP and prompted by developing nation and activist concerns over the credibility of emissions reduction commitments, characterized "a deficit of credibility and a surplus of confusion over emissions reductions and net zero targets, with different meanings and different metrics." The Secretary General therefore announced that he will "establish a Group of Experts to propose clear standards to measure and analyze net zero commitments from non-state actors." The Secretary General reiterated his intent to establish a high level group for this purpose at the conclusion of the COP as well. These will likely complement a range of emerging national financial sector and ESG transparency requirements, including the announcement of the formation of a new International Sustainability Standards Board, along with other Paris Climate Agreement provisions, particularly the new carbon market rules.
Indeed, youth activists expressed particular concern over the pace and credibility of emissions reduction commitments, stating quite simply that "we don't believe you" and urging the business community to "prove them wrong." This skepticism was heightened by the overall context of the final COP debate around the failure to honor in a timely way climate finance commitments of $100 billion per year to affected developing countries, the absence of a clear loss and damage compensation commitment, and the somewhat relaxed treatment of fossil fuels, particularly the insistence by some nations to preserve an ongoing role for coal.
Just as there will be these formal processes to help refine net zero expectations, there no doubt also will be enhanced activist group scrutiny of company pledges and climate impacts. Companies will be called to task to demonstrate what they are doing to implement their net zero commitments.This scrutiny is likely to be even more acute given the inability of the formal negotiating process to achieve a level of ambition through country NDCs that will reach the 1.5 degree target or deliver in the short term the climate finance commitments for the developing world and the credibility gap that this outcome may perpetuate. As France's former Climate Ambassador and the key architect of the Paris Climate Agreement, Laurence Tubiana, put it, "Greenwashing is the new climate denial." Climate accountability in many ways will be the new currency.
We Can Expect More Focus on Climate Commitments Going Forward
Building on the Paris accord, the agreement follows the pattern of existing domestic environmental laws in recognizing that it may not be a perfect solution, in and of itself, and that the science will continue to evolve.But those frameworks recognize that it is critical to get started on the emissions reduction process even if the target may be revised in the future. Similar to the Clean Air Act's five year review provision for fundamental health-based pollutants, Glasgow acknowledges the need to calibrate future emissions reductions based on new science more frequently and with greater transparency to assess the success of country measures in meeting the emissions targets, and that there is a fierce urgency of the now being expressed by climate advocates that should inform those evaluations. While the global community has demonstrated that it can, in essence, walk and chew gum at the same time, the question this time is whether it can do so while running.That will be tested starting next year with submissions to the next COP.
Implementation of the various COP26 pledges will be a critical piece of the equation. The test will continue to be how to turn commitments into action for this decade. As the UN Secretary General indicated, "COP27 begins today." In some ways, Glasgow represents a sharper focus on science-aligned plans — by governments and business and in the face of a new global climate consciousness — to maintain climate stability, and the focus will now shift to the implementation and refinement of those commitments. For companies, growing global climate consciousness and risks and opportunities posed by the energy transformation present a new post-Glasgow dynamic necessitating climate engagement, but requiring a credible approach in doing so.
类似拟议规则,最后规则为完成环境影响说明设定2年和完成环境评估设定1年的推定时限,除非牵头机构高级官员书面核准更长时间并设定新时间限 。
Final规则还为NEP文件设定推定页限EIS目前限页或小于150页,EA最多75页(不包括附录)“除非高级代理官书面批准EIS或EA可能超出推定页限并设定新页限关于异常范围或复杂度提案,推定页数限制为300.
Final规则还允许申请方和承包商在机构监督下扩大EIS或EAs编译作用万博体育app手机登录The Final Rule includes regulations that require the decision-making or lead agency to provide guidance, independently evaluate the EIS or EA, and take ultimate responsibility for the accuracy, scope, and content of the assessment.
Prior NEPA regulations defined "categorical exclusion" (CE) as a "category of actions which do not individually or cumulatively have a significant effect on the human environment and which have been found to have no such effect in procedures adopted by a Federal agency in implementation of these regulations … and for which, therefore, neither an environmental assessment nor an environmental impact statement is required." 40 C.F.R.§1508.4(旧规程)。终极规则修改定义,删除术语“单数或累积数”。§ 1508.1(d).
Final规则进一步补充称,如果aId 此前,代理机构会评价项目“异常环境”,这可能使通常排除项目接受审查,因为对环境产生重大不利影响终极规则维护此过程,但修改后规定,如果“异常情况存在,机构可绝对排除提议的行动,如果机构确定有情况可减少撞击或足以避免重大效果的其他条件。” 40 C.F.R.§1501.4(b)(1).
Simliarly,Final规则描述三级审查(EA、EIS和CEs)并增加一节题为“确定NEPA审查的适当级别”,规定各机构应以何种方式确定NEPA项目需要哪一级审查C.F.R.§1501.3.
最后规则还修改单列定义“主要联邦行动”,明确排除“治外活动或决定”、“非全权活动”、“非联邦项目最小联邦供资或控制,以及贷款、贷款担保或其他形式的金融援助等,如果联邦机构对援助结果不行使足够的控制和责任。Id §1508.1(q).下一步,Final规则不“包括机构因有限法定权限而无能力预防或不论拟议行动而发生”。 Id .
此外,终极规则明确指出,这是一项须接受国会根据国会审查法审查的“主要规则”,并因此CEQ将向国会和政府问责局提交包括最后规则在内的报告供审查规定最终规则自9月14日2020生效,如果国会审查改变生效日期,CEQ将在联邦注册局发布文件以确定实际生效日期或终止规则鉴于这种可能性和可能提出法律挑战的可能性,对受NEPA项目感兴趣的当事方希望监测这些动态公司执行受NEP约束项目时,可能欢迎简化和加速NEP进程的变化,但它们应认真考虑如何在不确定期间最优保护期望结果。
Nine Northeast and Mid-Atlantic states and the District of Columbia announced this week a new regional initiative to cap and reduce greenhouse gas pollution from the transportation sector. Much remains to be decided before the program takes effect, however.
Connecticut, Delaware, Maryland, Massachusetts, New Jersey, Pennsylvania, Rhode Island, Vermont, Virginia, and Washington D.C.[1] aim to cap carbon emissions from combustion of transportation fuels, and invest the proceeds into low-emission and improved transportation infrastructure, including by aiding electric vehicle adoption, and increasing public transit and biking opportunities.
The initiative is yet another example of state governments aggressively moving to regulate climate change issues, while the federal government has sought to reverse the prior administration's signature climate policies, proposing to roll back fuel economy standards and ease power plant regulations. California and New York are the largest states that have announced aggressive emission reduction and clean energy goals. Among the signatories to the new transportation initiative, Massachusetts and Connecticut have adopted goals, and the District of Columbia's clean energy legislation is awaiting the Mayor's signature.
By choosing to address transportation emissions, the initiative expands the regional coordination that several of these states have demonstrated in reducing emissions from the power sector through their participation in the Regional Greenhouse Gas Initiative (RGGI), a cap-and-trade program for power plant emissions in northeastern states.RGGI has had a relatively limited impact upon power sector emissions, however, such that its members have had to seek to better align market incentives with their own decarbonization goals through other means, such as establishing a separate cap upon power plant emissions within the state, or proposing an additional carbon price on electricity generators equivalent to the social cost of carbon. The RGGI member states could have followed the lead of California's economy-wide cap-and-trade program that includes emissions from both the electricity and transportation sectors by expanding RGGI to include transportation emissions.By choosing instead to establish a separate cap for the transportation sector, these states are charting a new path in seeking to address carbon pollution in the absence of federal leadership.
Many critical details remain to be decided: The states agreed only on the shared goal of negotiating a cap-and-reduce policy proposal for transportation fuels, to be completed over the next year. The level at which emissions will be capped, monitoring and reporting mechanisms, timelines for adoption, and even what industry is regulated under the system, are all to be determined. States would then have to formally join the initiative through their internal political processes before any restrictions would take effect.
Notwithstanding the remaining steps, however, the initiative is a major announcement. The participants represent roughly 17.5 percent of U.S.国产总值本身将成为世界第五大经济体,先于英国。 解决交通部门问题的决定也很重要,正如近些年来所见 https://rhg.com/research/final-us-Emissions-numbers-for2017/'eclipsed
>>1纽约州尽管主办两次利益攸关方会议宣布前,但尚未加入该举措。
s更多公司确认增强可持续性报告的价值并宣传其产品和服务积极的环境特征,他们也应该关注公众对绿化主张的更多监督。 参与绿化-夸大、误报或非物质环境主张-的公司越来越多地接触名声损害和法律大战,监管者、投资人和民间社会行为方投入更多资源审查环境主张公司还面临来自投资者越来越大的压力,要求发布标准化严格可持续性信息,允许跨行业基准化。 advancedserfs/sasb.org/servsb/a联邦贸易委员会继续通过执法行动控制环境营销空间,最突出的是它s/www.ftc.gov/force/cases-procedings/162-3006/volkswagen-group-america-inc短短五年内,环境、社会治理投资策略下管理的资产s/irrcinstice.org/wp-content/uploads/+17/04/FinalIRRCiReport_HowInvestorsIntegrateESG.ATTyproaches.pdf响应>Ernst&Young 调查,68%的机构投资者回答说非金融性能常或偶而在前一年决策中起关键作用。
i规程设定州专用二氧化碳排放目标及州守法指南EPA预测,到2030年,根据条例进行的州级改革将使CO2 从2005年水平在全国下降30%79 Fed.瑞格34829,34832(2014年6月18日) 2013年总统备忘录最初要求2015年6月发布日期,但根据议程,规则现将于8月某个日期定稿规则最终发布定在同月完成新电厂、改型电厂和重构电厂的温室气体标准8月综合规范最终定案将同国会夏季休课同时并发 。
Also在空气和辐射战线上,EPA正按期发布经修订的臭氧标准,供公众健康和福利使用EPA自2000年代中期开始逐步修订标准,从0.800分/百万分数下降2008年Columbia巡回上诉法院维护订正公众健康标准0.075ppm,但还押EPA进一步审查相同的修订福利标准EPA正修改初级和二级标准新低值0.065-0.070 ppm,面向儿童、老年人、哮喘和其他肺病患者等“危难者”。79 Fed.瑞格7523375233617,2014年 新标准近期内将增加非实现区数,已经引起立法者注意。俄克拉荷马州参议员Jim Inhofe(R),参院环境与公共工程委员会主席,
7月将提出更新数十年标准的建议, 以减少近海水井天然气排空、燃烧和泄漏The proposed rule is expected to "establish requirements and incentives to reduce waste of gas and clarify when royalties apply to lost gas." The final action date is currently set for June 2016.
Other agency actions set for this summer include:
The flurry of upcoming activity comes on the heels of the finalization of the "Waters of the United States" rule on May 27, 2015.规则定义s/www.insideEnergyandense.com/2014/04/epa-and-acoe-propose-new-ruce-clarity-the-term-waters/反对者辩称,这有违国会和最高法院设置的限制规则最终定案可能是春季议程中首个政治争议性行动,但不是最后行动 。