Comparative analysis of environmental legislation

This report provides a comparative analysis of environmental legislation across the EU, UK, US, Canada, and New Zealand, focusing on the scope of environmental laws, the explicit mention of climate change, and the mechanisms for impact assessments.

• The EU's Environmental Impact Assessment (EIA) Directive requires member states to assess environmental impacts, including greenhouse gas (GHG) emissions, for projects such as refineries, oil extraction exceeding 500 tonnes/day, and gas and oil pipelines. While the EU provides guidance for integrating climate change into these assessments, the effectiveness of this process varies among member states due to differences in enforcement, resources, and implementation.
• The UK Environment Act 2021 establishes binding targets for waste reduction, biodiversity, water, and air quality, and created the Office for Environmental Protection (OPE) for enforcement. While the Act emphasizes addressing climate change and mandates collaboration between the OPE and the Committee on Climate Change, it does not include impact assessment measures; these are instead handled by the Environmental Impact Assessment (EIA) process and the Climate Change Act 2008 (CCA), the latter of which introduced legally binding national carbon budgets.
• The US National Environmental Policy Act (NEPA) lacks a specific mention of climate change, though the Council on Environmental Quality (CEQ) provides guidance on integrating climate considerations and adaptation measures. Following a study that found insufficient climate change consideration in federal energy project reviews, the CEQ proposed reforms in July 2023 to increase the emphasis on environmental justice and climate change in major federal project assessments.
• In Canada, the Canadian Environmental Protection Act, 1999 (CEPA) does not explicitly mention climate change or address project environmental assessments. These assessments are managed by the Impact Assessment Act (IAA), which triggers automatic assessments for fossil fuel projects exceeding 200 MW capacity or coal mines over 5,000 tonnes per day. However, a review of the IAA found that it does not require assessments for small-scale fossil fuel projects.
• New Zealand's Resource Management Act 1991 (RMA) requires local authorities and government representatives to have particular regard for climate change effects. For fossil fuel activities, applicants must demonstrate that low-emission alternatives are infeasible, unless emissions are under 500 tonnes of CO2 per year. By the end of 2023, the government intends to replace the RMA with three new frameworks to improve national environmental performance and address adaptation funding and climate change challenges.

APA

Zero Carbon Analytics (n.d.). Comparative analysis of environmental legislation. https://zerocarbon-analytics.org//wp-content/uploads/2023/11/Comparative-analysis-of-environmental-legislation.pdf

Chicago

Zero Carbon Analytics. Comparative analysis of environmental legislation. n.d. https://zerocarbon-analytics.org//wp-content/uploads/2023/11/Comparative-analysis-of-environmental-legislation.pdf.

Wikipedia

{{cite report |author=Zero Carbon Analytics |title=Comparative analysis of environmental legislation |url=https://zerocarbon-analytics.org//wp-content/uploads/2023/11/Comparative-analysis-of-environmental-legislation.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{zerocarbonanalyticsndcomparative, author = {{Zero Carbon Analytics}}, title = {{Comparative analysis of environmental legislation}}, institution = {Zero Carbon Analytics}, url = {https://zerocarbon-analytics.org//wp-content/uploads/2023/11/Comparative-analysis-of-environmental-legislation.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }