Report on Montana’s Greenhouse Gas Assessment Guidance and Alignment with Sustainable Development Goals

1.0 Introduction: Advancing Climate Action through Institutional Processes

The Montana Department of Environmental Quality (DEQ) has initiated a public consultation process for new guidance on the collection and analysis of greenhouse gas (GHG) emissions in environmental reviews. This initiative directly addresses SDG 13 (Climate Action) by establishing a standardized framework for assessing climate impacts. The process also reinforces SDG 16 (Peace, Justice, and Strong Institutions) by promoting transparent and participatory environmental governance.

2.0 Legislative and Judicial Context

The development of this guidance is mandated by Senate Bill 221, which seeks to balance environmental oversight with economic development objectives, reflecting the interplay between several Sustainable Development Goals.

• Legislative Mandate (SB 221): Signed by Governor Greg Gianforte, the bill aims to create a clear GHG assessment methodology. The stated goal is to prevent regulatory delays for industry and development, aligning with SDG 8 (Decent Work and Economic Growth) and SDG 9 (Industry, Innovation, and Infrastructure).
• Judicial Precedent (Held v. Montana): This legislative action follows a 2025 Montana Supreme Court ruling which affirmed that the state’s constitutional right to a “clean and healthful environment” includes a stable climate. This landmark decision firmly grounds state environmental policy within the framework of SDG 13 (Climate Action).
• Policy Tension: The subsequent legislative response, including the Montana Environmental Policy Act (MEPA) reform package, highlights a perceived conflict between judicial interpretations of environmental protection and legislative priorities for economic growth and industrial development.

3.0 Framework for GHG Assessment and Sustainable Production

The DEQ’s draft guidance document, published on October 1, provides a framework for state agencies to evaluate GHG emissions. This framework is critical for integrating climate considerations into development, supporting SDG 12 (Responsible Consumption and Production).

3.1 Scope of Assessment

The guidance mandates GHG assessments for projects that significantly impact climate stability, including:

1. All fossil fuel projects, directly impacting SDG 7 (Affordable and Clean Energy) by scrutinizing carbon-intensive energy sources.
2. Projects involving stationary combustion devices.
3. Activities with significant construction and mobile engine operation.
4. Projects affecting ecological functions related to carbon sequestration.

3.2 Methodology

The document outlines specific methodologies for agencies to:

• Define relevant GHGs (carbon dioxide, methane, nitrous oxide, and fluorinated gases).
• Calculate emissions based on project size and type.
• Provide both qualitative and quantitative analysis of the secondary impacts of GHG emissions on the human environment, contributing to the holistic goals of SDG 11 (Sustainable Cities and Communities).

4.0 Public Participation and Partnership for the Goals

The DEQ is actively seeking “substantive public comments” to finalize the guidance, embodying the principles of SDG 16 (Peace, Justice, and Strong Institutions) and fostering SDG 17 (Partnerships for the Goals).

4.1 Submission of Comments

Comments can be submitted through the following channels until the end of the month:

• Email: DEQGHG@mt.gov
• Mail:
  Montana Department of Environmental Quality
  Attn: Craig Jones
  PO Box 200901
  Helena, MT 59620-0901

4.2 Public Listening Sessions

Three public listening sessions will be held to gather feedback. All sessions will be accessible in person and via Zoom stream.

1. October 27, 6 p.m. – 8 p.m.: Billings Hotel and Convention Center, 1223 Mullowney Ln, Billings, MT 59101.
2. October 29, 6 p.m. – 8 p.m.: University Center South Ballroom, The University of Montana, 32 Campus Dr, Missoula, MT 59812.
3. October 30, 2025 6 p.m. – 8 p.m.: Delta Hotel, 2301 Colonial Dr, Helena, MT 59601.

Analysis of Sustainable Development Goals in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

1. SDG 13: Climate Action
   • The article’s central theme is the management and assessment of greenhouse gas emissions, which is the primary focus of SDG 13. The Montana Department of Environmental Quality (DEQ) is developing guidance on how to “collect and analyze greenhouse gas emissions,” directly addressing the need to combat climate change and its impacts. The mention of specific gases like “carbon dioxide, methane, nitrous oxide, and fluorinated gases” reinforces this connection.
2. SDG 16: Peace, Justice and Strong Institutions
   • The article details the development of state-level policy and institutional frameworks. It discusses the creation of legislation (Senate Bill 221), the influence of a state Supreme Court decision (Held v. Montana), and the DEQ’s effort to create a new guidance document. Furthermore, the process of seeking “substantive public comments” and holding “listening sessions” demonstrates an effort to build effective, accountable, and transparent institutions that engage in participatory decision-making.
3. SDG 11: Sustainable Cities and Communities
   • The new guidance for environmental reviews applies to development projects that impact communities. The article specifies that assessments are required for projects involving “construction and mobile engine operation,” which are activities that directly affect the environmental quality and sustainability of human settlements.
4. SDG 7: Affordable and Clean Energy
   • The article explicitly states that under the new bill, state agencies “must conduct a greenhouse gas assessment for all fossil fuel projects.” This directly links the environmental policy to the energy sector, highlighting the state’s approach to regulating the environmental impact of fossil fuel-based energy production.

2. What specific targets under those SDGs can be identified based on the article’s content?

1. Target 13.2: Integrate climate change measures into national policies, strategies and planning.
   • The entire effort described in the article—developing a guidance document for greenhouse gas assessments as part of the Montana Environmental Policy Act (MEPA)—is a clear example of integrating climate change measures into state-level environmental policy and planning processes.
2. Target 16.6: Develop effective, accountable and transparent institutions at all levels.
   • The DEQ’s process of publishing a draft document for public review and actively seeking input is an action aimed at creating a transparent and accountable institutional process. The article quotes the DEQ director saying, “These will be very open and transparent processes, and we look forward to engaging with the public.”
3. Target 16.7: Ensure responsive, inclusive, participatory and representative decision-making at all levels.
   • The state is actively encouraging public participation by seeking “substantive public comments” and holding three public “listening sessions” in different cities, which will also be streamed online. This demonstrates a commitment to inclusive and participatory decision-making in the formation of the new environmental guidance.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

1. Indicator 13.2.2: Total greenhouse gas emissions per year.
   • The article implies the use of this indicator by stating that the new guidance provides a framework for how agencies should “calculate emissions from a project.” The document defines greenhouse gases (carbon dioxide, methane, etc.) and outlines methods for “gathering and evaluating greenhouse gas emission data.” This data collection is a prerequisite for tracking total emissions.
2. Indicator 16.7.2: Proportion of population who believe decision-making is inclusive and responsive.
   • While the article does not measure this indicator, it describes the actions that contribute to it. The establishment of a public comment period, the scheduling of multiple public listening sessions, and the provision of online access are all mechanisms designed to make the decision-making process more inclusive and responsive to public input. The existence of these participatory processes is a qualitative measure related to this indicator.

4. SDGs, Targets and Indicators Table

Source: dailymontanan.com