COMMENTS ON GUIDELINES FOR IMPLEMENTATION OF EXECUTIVE ORDER 13141 (“ENVIRONMENTAL REVIEW OF PROPOSED TRADE AGREEMENTS”)

A coalition of environmental organizations provides detailed recommendations to the U.S. government on implementing Executive Order 13141. They argue for the full integration of environmental reviews into all stages of trade negotiations, the adoption of a comprehensive analytical framework that considers global and cumulative impacts (including greenhouse gas emissions), and a functional approach to identifying agreements that require scrutiny. The coalition emphasizes the need for transparency, public participation, and the use of specialized agency expertise over the limited capacity of the USTR.

• The coalition argues that the primary goal of Executive Order 13141 should be the full integration of environmental considerations into the entire trade policy process, rather than treating environmental reviews as a mere procedural end in themselves.
• The authors recommend that environmental assessments be triggered at every significant stage of trade negotiations, starting from the initial contemplation of negotiations and continuing through implementation. This process should begin with an examination of baseline environmental conditions to identify existing market and policy failures before trade proposals are set.
• The document proposes a detailed analytical framework for environmental reviews, which includes identifying trade measures, economic effects (such as structural changes in sectors), regulatory effects (including downward pressure on standards), and foreseeable environmental effects. It emphasizes the need to evaluate cumulative impacts of overall trade policy and consider alternatives, including a 'no-action' alternative.
• The coalition asserts that the U.S. must include global and transboundary environmental impacts in its reviews, citing the U.S. position as the world's largest emitter of anthropogenic greenhouse gases and its significant influence on global fossil fuel imports and exports.
• The authors advocate for a 'functional approach' to determining which agreements require review, suggesting that any negotiation likely to have significant environmental implications should be scrutinized, regardless of whether it fits a strict legal definition of a 'comprehensive multilateral trade round' or 'bilateral' agreement.
• The document emphasizes that the USTR lacks the internal capacity for detailed environmental assessment and should rely on the technical expertise of other federal, state, and local agencies, ensuring that the agencies with the most relevant mandates maintain lead authority over their specific findings.

APA

Center for International Environmental Law (n.d.). COMMENTS ON GUIDELINES FOR IMPLEMENTATION OF EXECUTIVE ORDER 13141 (“ENVIRONMENTAL REVIEW OF PROPOSED TRADE AGREEMENTS”). https://www.ciel.org/wp-content/uploads/2015/03/EO13141Comments.pdf

Chicago

Center for International Environmental Law. COMMENTS ON GUIDELINES FOR IMPLEMENTATION OF EXECUTIVE ORDER 13141 (“ENVIRONMENTAL REVIEW OF PROPOSED TRADE AGREEMENTS”). n.d. https://www.ciel.org/wp-content/uploads/2015/03/EO13141Comments.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=COMMENTS ON GUIDELINES FOR IMPLEMENTATION OF EXECUTIVE ORDER 13141 (“ENVIRONMENTAL REVIEW OF PROPOSED TRADE AGREEMENTS”) |url=https://www.ciel.org/wp-content/uploads/2015/03/EO13141Comments.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallawndcomments, author = {{Center for International Environmental Law}}, title = {{COMMENTS ON GUIDELINES FOR IMPLEMENTATION OF EXECUTIVE ORDER 13141 (“ENVIRONMENTAL REVIEW OF PROPOSED TRADE AGREEMENTS”)}}, publisher = {Center for International Environmental Law}, url = {https://www.ciel.org/wp-content/uploads/2015/03/EO13141Comments.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }