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Analysis of NEPA Reviews for Fossil Fuel Projects

Updated: Aug 31, 2023

Summary: Analysis of seven Environmental Impact Statements issued in 2022 and 2023 for major fossil fuel projects — including Willow, CP2 LNG, Alaska LNG, and onshore/offshore leases — finds that agencies systematically understated greenhouse gas emissions from oil and gas projects by an average of 98%. The presumption in many EIS's that new fossil fuel supplies will not significantly affect energy and emissions pathways acted as a self-fulfilling verdict, leading to inaccurate information for decision-makers and significantly distorting greenhouse gas emissions estimates. The net result is that 18 gigatons of emissions (CO2e) and more than $1 trillion of climate damages were obscured across the 7 EISs. By comparison, total U.S. domestic greenhouse gas emissions are about 5 gigatons annually, across all sources.

At its heart, the National Environmental Policy Act (NEPA) is about making better decisions based on accurate and transparent information. Accuracy is especially important when assessing the climate impacts of fossil fuel projects that could lock in new sources of climate pollution for decades.

A 2023 report by Jan Hasselman and Peter Erickson sheds light on a recurring problem as EISs fail to accurately account for the full climate impact of fossil fuel projects. They write:

"There are now many examples of agencies assuming that if a project is not approved, some other entity would produce, transport, or consume all or nearly all of the fossil fuels that would be produced or transported by the project under review. This results in a poorly supported and likely incorrect finding that the project has little or no impact on long term GHG emissions—or even a net benefit if it displaces a less GHG-intensive source of fuel." - Hasselman and Erickson

To explore this problem further, Symons Public Affairs analyzed seven EIS’s issued by federal agencies for major fossil fuel projects since 2022 in draft or final form, including:

  • Willow (BLM, 2023, Final SEIS)

  • Alaska LNG (DOE, 2023, Final SEIS)

  • CP2 LNG (FERC, 2023, Final EIS)

  • Mountain Valley Pipeline (US Forest Service, 2023, Final SEIS)

  • Gulf of Mexico oil & gas lease sales 259 & 261 (BOEM 2023, Final SEIS)

  • Buffalo (Wyoming) Field Office’s Resource Management Plan for coal leasing (BLM, 2023, Draft SEIS)

  • Outer Continental Shelf oil & gas leasing 5-year plan (BOEM, 2022, Draft EIS)

The data for this analysis are available in the attached file. A summary is provided in the table below, followed by key findings.

GHG and Social Cost of Carbon Data from EISs

of Seven Major Fossil Fuel Projects

Notes: GHG and SCC figures represent the high end of the range where ranges were provided (see attached data set for details). With the exception of BLM's Resource Management Plan for Buffalo Field Office, the data shown here is cumulative over the lifetime of the project (usually 30 years). The data shown for BLM's Resource Management Plan includes only the impact of new coal leases through 2048 within the boundaries of the Buffalo Field Office in Wyoming. BLM estimates that existing leases will produce 6,962 MMT of emissions and $1.0 trillion in damages within the zone, and that new leases within this zone have potential for up to 79.3 gigatons over 300 years.


  • All six EIS's for oil and gas projects failed to fully account for greenhouse gas impacts. Two EIS's (MVP and CP2 LNG) failed to provide full lifecycle emissions estimates. The remaining four EIS's used assumptions about substitution that deducted, on average, 98% of the climate impacts (reducing the combined footprint from 10.2 gigagtons CO2e to 0.2 gigatons).

"No Action Alternative 1 compared to the Proposed Action scenarios summarizes the GHG effects based on the global perspective that if LNG and oil were not produced from this Project, they would be produced from another global source and result in GHG emissions" - DOE, Alaska LNG SEIS
  • In its FEIS for CP2 LNG, FERC dismissed comments from EPA on the need to include full lifecycle greenhouse gas emissions, including upstream and downstream emissions:

"Federal agencies have a legal obligation to consider direct and indirect impacts associated with a project including upstream and downstream emissions caused by production, processing, transportation, and consumption of the project’s resources." - EPA Comments to FERC on CP2 LNG draft EIS
"...NEPA does not require the Commission to consider the upstream or downstream GHG emissions that may be indirect effects of the export itself ..." - FERC CP2 LNG Final EIS
  • One EIS (BLM Buffalo Field Office coal leasing) included full lifecycle greenhouse gas emissions without deducting emissions for substitution.

  • Data from the five EIS's that included lifecycle GHGs show a combined GHG emissions footprint of 12.5 gigatons of greenhouse gases (CO2e) over the next 30 years. 12.5 gigatons are equivalent to two years of total U.S. emissions from all sources.

  • According to the EIS data, the combined climate damages (i.e., "Social Cost of Carbon") from the five projects could be as high as $1 trillion.

  • Independent estimates suggest that the two projects (Mountain Valley Pipeline and CP2 LNG) whose lifecycle emissions were not calculated in the EIS could account for an additional 8 gigatons of greenhouse gas emissions over their lifetimes.

  • Where federal agencies used substitution assumptions, they often favored these results as the bottom line conclusion, characterizing the impacts as “incremental” or “very similar.”

"Finally, the Project would increase the atmospheric concentration of greenhouse gases (GHG) in combination with past, current, and future emissions from all other sources and would contribute incrementally to future climate change impacts" - FERC, CP2 LNG FEIS
  • None of the EISs that deducted greenhouse gas emissions for substitution based these assumptions on scenarios where net-zero emission goals are met. Rather, they assumed high fossil fuel demand through 2050.

"...estimates assume current patterns of energy consumption and are based on current policies and laws, but do not include the overarching national policy to achieve net-zero GHG emissions by 2050 ... therefore the model’s substitution emission estimates overall should be understood to be uncertain and potentially significantly higher than if new requirements were set to achieve the 2050 net-zero target." - BOEM, 5-year OCS SEIS
  • None of the EISs that deducted greenhouse gas emissions for substitution applied the same substitution arguments to discount the potential revenues or economic benefits of the project, an inconsistency that underscores the unique and arbitrary nature by which agencies discount greenhouse gas emissions.

The bottom line: the presumption that new fossil fuel supplies will not significantly affect energy and emissions pathways is a self-fulfilling verdict, leading to inaccurate information for decision-makers and significantly distorting greenhouse gas emissions estimates.

[Updated Aug. 31, 2023 for clarity]

Analysis of Major Fossil Fuel EISs Since 2022 by Symons Public Affairs August 2023
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