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.