NEPA Revised Draft Guidance on Consideration of GHG Emissions: Version 2.0 - Proposal Requires Federal Agencies to Assess GHG and Climate Change Impacts and Encourages Substantive GHG Reductions Under the National Environmental Policy Act NEPA's Revised Draft Guidance could require a significant level of additional analysis, including analysis of "upstream" and "downstream" impacts as well as a cost-benefit analysis in certain circumstances. The proposed guidance goes well beyond the well-established NEPA non-substantive "hardlook" doctrine by instructing agencies to use the NEPA process to force the substantive reduction of GHG emissions.