Calthos is a hybrid NEPA advisory firm focusing on pro bono NEPA consulting for tribal nations or wilderness advocates — reviewing EIS documents, identifying vulnerabilities, and helping communities on how to engage. In the era of decentralized NEPA regulations and AI, we believe NEPA requires transparency and that federal agencies must document AI use, data sources, and maintain accountability. Increased global warming facts are irrefutable: glacial retreat, warming oceans, ocean acidification, sea level rise, declining Arctic Sea ice, extreme events, decreased snow cover, shrinking ice sheets, shrinking lakes, and global temperature rise since the late 19th century. According to NOAA’s Earth System Research Laboratories, Global Monitoring Laboratory (GML) the average of smoothed seasonal curves and smoothed, de-seasonalized trends of daily mean CO2 data from the four GML Atmospheric Baseline observatories: Barrow, Alaska; Mauna Loa, Hawaii; American Samoa; and South Pole, Antarctica was 427.71 ppm on May 22, 2026. Global warming will impair those ecosystems, including the human environment, that cannot adapt quickly enough to the changes it causes.
Global warming could theoretically be combated by incorporating greenhouse gas (GHG) and energy analyses through the NEPA process, although this will be more difficult without the CEQ NEPA Regulations. On February 25, 2025, CEQ published an Interim Final Rule (IFR) in the Federal Register to remove its NEPA implementing regulations from the Code of Federal Regulations (40 CFR Parts 1500–1508), effective April 11, 2025. The IFR went into effect on April 11, 2025, removing CEQ's NEPA regulations pursuant to President Trump's direction in his "Unleashing American Energy" Executive Order 14154, January 20, 2025, to expedite and simplify the permitting process. Because it was an interim final rule, CEQ opened a 30-day public comment period through March 27, 2025. The CEQ regulations were removed on April 11, 2025 while those comments were still being reviewed. On January 8, 2026, CEQ published a final rule adopting — without change — the February 2025 IFR. The final rule primarily responded to comments submitted on the IFR and reaffirmed CEQ's position that, following the rescission of Executive Order 11991, CEQ lacked authority to maintain binding, government-wide NEPA regulations applicable to other federal agencies. The practical takeaway is that the April 2025 action did the actual work of removing the regulations, while the January 2026 rule was a procedural finalization meant to make that rescission legally bulletproof against Administrative Procedure Act challenges. What we have now is tantamount to replacing a single national baseball rulebook with dozens of team-specific playbooks--same game, different rules depending on who is in charge.