Comparative analysis of environmental legislation

The document compares how different jurisdictions integrate climate change into environmental law. It finds that while the EU and New Zealand have explicit requirements for climate considerations in assessments, the US and Canada rely on guidance or separate acts rather than the primary environmental laws. The UK uses a combination of the Environment Act 2021 and the Climate Change Act 2008 to manage emissions and accountability.

• 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 and oil extraction exceeding 500 tonnes/day, though effectiveness varies by state due to implementation and resource differences.
• The UK's Environment Act 2021 establishes the Office for Environmental Protection (OPE) and mandates collaboration with the Committee on Climate Change, but it does not include its own impact assessment measures; instead, GHG assessments are handled by the Climate Change Act 2008 and the EIA process.
• The US National Environmental Policy Act (NEPA) does not specifically mention climate change, though the Council on Environmental Quality (CEQ) provides guidance on integrating climate considerations. In July 2023, the CEQ proposed NEPA reforms to increase emphasis on climate change and environmental justice.
• In Canada, the Canadian Environmental Protection Act, 1999 (CEPA) does not mention climate change or address project assessments; these are handled by the Impact Assessment Act (IAA), which triggers automatic assessments for coal mines over 5,000 tonnes per day or fossil fuel projects exceeding 200 MW capacity.
• New Zealand's Resource Management Act 1991 (RMA) requires authorities to consider climate change effects and GHG emissions for resource consent applications, requiring applicants for fossil fuel activities to prove low-emission alternatives are infeasible unless emissions are under 500 tonnes of CO2 per year. The government plans to replace the RMA with three new frameworks by the end of 2023.

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} }