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should continue to evaluate the possible wetlands impacts associated with the NEPA Preferred Alternative and identify specific mitigation measures to ensure the least impact possible to these special water resources. C. Air Quality The DEIS's cursory examination of air quality impacts does a disservice to the project by failing to document the significant positive effects the D -0 LRT will have on air quality. While "[ m]odeling analyses are only required for areas that are in nonattainment or maintenance for a particular pollutant" in terms of National Ambient Air Quality Standards ( "NAAQS ") under the Clean Air Act, the FEIS should discuss more of the air quality impacts than are discussed in the DEIS. n The DEIS identifies that Durham County is a maintenance area for carbon monoxide and then limits air quality discussion to this sole pollutant and area. Even if modeling analyses are not required, the FEIS should document and consider the possible air quality impacts that will result from this project. For example, the FEIS should note that by reducing the numbers of cars on the road, there will be a corresponding reduction in multiple harmful pollutants. Moreover, even if additional modeling analyses are not required, they certainly are not prohibited, and we would support GoTriangle conducting further modeling analyses to document the positive effects this system will have on air quality. D. Greenhouse Gas Emissions One of the prime environmental benefits of the D -0 LRT is the potential for reductions in tailpipe emissions of GHGs. In December 2014, the Council of Environmental Quality ( "CEQ ") issued a draft guidance on "Consideration of Greenhouse Gas Emissions and the Effects of Climate Change," under NEPA. 72 The draft guidance instructs agencies to consider impacts on GHGs when conducting a NEPA analysis. The DEIS failed to conduct such an analysis, citing a lack of a "national strategy to address greenhouse gas emissions from transportation," and asserting that "[i]t is technically unfeasible to accurately model how negligible increases or decreases of CO2 emissions at a project scale would add or subtract to the carbon emissions from around the world." 73 We disagree with this sentiment. As recognized by the CEQ's draft guidance, while "climate impacts are not attributable to any single action," they are "exacerbated by a series of smaller decisions, including decisions made by the government" and should be analyzed as such .74 Here, the D -0 LRT's impact would almost certainly have the positive environmental effect of reducing GHGs. Documenting such a positive effect is important for future transportation planning and to establish the precedent of conducting such evaluations. 71 The FEIS should also clarify that 40 C.F.R. 93, subpart A, requires modeling analyses for only nonattainment or maintenance areas for a given pollutant. While reference is made in Appendix K23, the source of this requirement should be clarified within the text of the FEIS. 72 Revised Draft Guidance on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change, 79 Fed. Reg. 77801 (Dec. 24, 2014). 73 DEIS at 4 -201. 74 Revised Draft Guidance, 79 Fed. Reg. at 77825. 13