On August 26, 2019, NRECA joined APPA in filing comments to the CEQ on its draft NEPA greenhouse gas guidance. We are generally supportive of the guidance. We recommended the final guidance include language confirming the a federal agency’s scope of environmental review and analysis be focused on those effects that are caused by its action and are subject to its regulatory jurisdiction and control. In addition, we recommended that the proximate cause standard be used to assess indirect effects and cumulative impacts.