On December 18, 2014, the federal Council on Environmental Quality (CEQ) released draft guidance describing how federal departments and agencies should consider the effects of greenhouse gas emissions (GHGs) and climate change when conducting reviews under the National Environmental Policy Act (NEPA). 42 U.S.C. ch. 55.  The draft guidance supersedes a previous draft guidance that CEQ issued in 2010 but never finalized. The new draft guidance retains many core concepts of the 2010 guidance. For example, agencies must evaluate a proposed action’s impacts upon climate change, as indicated by GHG emissions, as well the implications of climate change for the proposed action’s environmental effects. The draft guidance also retains the 2010 proposed threshold for conducting a quantitative climate change analysis of 25,000 metric tons…