Partner Ted Boling was quoted in “CEQ's NEPA Proposal Returns Climate Impacts to Forefront of Analyses,” an article in Inside EPA, regarding the new proposal by the White House Council on Environmental Quality (CEQ) that floats three core changes for how agencies implement the National Environmental Policy Act (NEPA).

But Ted Boling, a former top CEQ NEPA official now in private practice at Perkins Coie, says the proposal is nuanced in seeking to address confusion caused by the 2020 rule and its potential effect on longstanding NEPA practices, rather than imposing new climate analysis mandates.

The rule does not seek to change how analyses are conducted but instead hopes to clarify that the 2020 rule was an "imperfect articulation" of case law that has implications for climate change and EJ analysis, Ted says. "Therefore, CEQ is returning some of the language back to how it appeared in the 1978 regulations."