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

The Center for International Environmental Law and partner organizations argue that Executive Order 13141 must be implemented with the political will to fully integrate environmental considerations into the earliest stages of trade policy-making. They propose a structured, iterative review process triggered at every significant step of negotiations, from the contemplation of talks to ongoing implementation. The authors advocate for a broad analytical framework that considers global and transboundary impacts, cumulative effects of trade policy, and the evaluation of alternatives, including 'no-action' options. They emphasize the necessity of maximizing public participation to restore democratic accountability and insist that environmental agencies, rather than the USTR alone, maintain lead authority over technical environmental findings.

• The implementation of EO 13141 should move beyond treating environmental protection as a side issue and instead fully integrate it into the development of trade negotiating objectives and the final text of agreements.
• The authors propose a seven-stage iterative review process to ensure environmental implications are considered throughout the life of a trade negotiation: contemplation of negotiation, declaration of intent, international agreement on elements, development of positions, development of draft text, international agreement on text/presentation to Congress, and ongoing review during implementation.
• The proposed analytical framework for environmental reviews should include identifying trade measures, economic effects, regulatory effects (such as 'downward pressure on standards'), foreseeable environmental effects, cumulative impacts of overall trade policy, and an objective evaluation of alternatives including the 'no-action' alternative.
• The U.S. should broadly interpret the scope of environmental reviews to include global and transboundary impacts, citing its role as the world's largest emitter of anthropogenic greenhouse gases and its international environmental responsibilities.
• To ensure technical integrity, the authors argue that lead authority for environmental analyses and findings should remain with the most competent federal agencies rather than being delegated to the USTR, which has limited capacity for such assessments.
• The document argues for a functional rather than mechanical interpretation of Section 4 of the EO, suggesting that reviews should be conducted whenever negotiations are likely to have significant environmental implications, regardless of whether they fit a strict legal category.

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} }