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171 <br /> should continue to evaluate the possible wetlands impacts associated with the NEPA Preferred <br /> Alternative and identify specific mitigation measures to ensure the least impact possible to these <br /> special water resources. <br /> C. Air Quality <br /> The DEIS's cursory examination of air quality impacts does a disservice to the project by <br /> failing to document the significant positive effects the D-O LRT will have on air quality. While <br /> "[m]odeling analyses are only required for areas that are in nonattainment or maintenance for a <br /> particular pollutant" in terms of National Ambient Air Quality Standards ("NAAQS")under the <br /> Clean Air Act, the FEIS should discuss more of the air quality impacts than are discussed in the <br /> DEIS.71 The DEIS identifies that Durham County is a maintenance area for carbon monoxide <br /> and then limits air quality discussion to this sole pollutant and area. Even if modeling analyses <br /> are not required, the FEIS should document and consider the possible air quality impacts that <br /> will result from this project. For example, the FEIS should note that by reducing the numbers of <br /> cars on the road, there will be a corresponding reduction in multiple harmful pollutants. <br /> Moreover, even if additional modeling analyses are not required, they certainly are not <br /> prohibited, and we would support GoTriangle conducting further modeling analyses to document <br /> the positive effects this system will have on air quality. <br /> D. Greenhouse Gas Emissions <br /> One of the prime environmental benefits of the D-O LRT is the potential for reductions in <br /> tailpipe emissions of GHGs. In December 2014, the Council of Environmental Quality("CEQ") <br /> issued a draft guidance on"Consideration of Greenhouse Gas Emissions and the Effects of <br /> Climate Change,"under NEPA.72 The draft guidance instructs agencies to consider impacts on <br /> GHGs when conducting a NEPA analysis. The DEIS failed to conduct such an analysis, citing a <br /> lack of a"national strategy to address greenhouse gas emissions from transportation," and <br /> asserting that"[i]t is technically unfeasible to accurately model how negligible increases or <br /> decreases of CO2 emissions at a project scale would add or subtract to the carbon emissions from <br /> around the world." 73 We disagree with this sentiment. As recognized by the CEQ's draft <br /> guidance, while "climate impacts are not attributable to any single action,"they are "exacerbated <br /> by a series of smaller decisions, including decisions made by the government" and should be <br /> analyzed as such.74 Here, the D-O LRT's impact would almost certainly have the positive <br /> environmental effect of reducing GHGs. Documenting such a positive effect is important for <br /> future transportation planning and to establish the precedent of conducting such evaluations. <br /> 71 The FEIS should also clarify that 40 C.F.R.93, subpart A,requires modeling analyses for only nonattainment or <br /> maintenance areas for a given pollutant. While reference is made in Appendix K23,the source of this requirement <br /> should be clarified within the text of the FEIS. <br /> 72 Revised Draft Guidance on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change, 79 <br /> Fed.Reg. 77801 (Dec.24,2014). <br /> 73 DEIS at 4-201. <br /> 74 Revised Draft Guidance, 79 Fed.Reg.at 77825. <br /> 13 <br />