E&E Legal was one of nearly twenty free market oriented groups who provided comments to the Honorable Michael Boots, Chair, regarding the National Environmental Policy Act (NEPA) review. In the summary, the letter said:
National Environmental Policy Act (NEPA) review is an inappropriate framework for making climate policy. Project-related greenhouse gas (GHG) emissions should not be a factor determining whether agencies grant or deny permits for individual projects. The Guidance endorses the alarmist perspective of EPA’s GHG endangerment finding, instructs agencies to quantify indirect (upstream and downstream) as well as direct emissions of individual projects, and recommends the use of social cost of carbon (SCC) calculations in cost-benefit analysis of projects. Each of those elements separately, and especially all in combination, will embolden anti-development groups and politicize rather than improve agency decisions. The Draft Guidance should be withdrawn.
The comments, which were sent to Chairman Boots on March 25, were organized and submitted by Marlo Lewis, Senior Fellow, Competitive Enterprise Institute.