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Comments on the Forest Service’s Use of the Social Cost of Carbon

January 15, 2016

In a proposed exception to the Colorado Roadless Rule, which provides for management of National Forest roadless areas where such activities as tree cutting and road construction are prohibited, the Forest Service analyzes the climate effects of its proposal. Though the agency’s choices to monetize greenhouse gas emissions and to use the Interagency Working Group’s estimates of the Social Cost of Carbon in its supplemental environmental impact statement are appropriate and necessary, its application of the metric is flawed in several respects.

We recently submitted comments regarding the Forest Service’s analysis, authored jointly with the Environmental Defense Fund, the Natural Resources Defense Council, and the Union of Concerned Scientists. Our comments make several key points:

  • Most importantly, the Forest Service’s use of a 10th percentile estimate misunderstands the treatment of uncertainty and risk built into the Interagency Working Group’s range of four estimates. Using a 10th percentile estimate is inconsistent with federal guidance and uniform agency practices, and it should not be used in this or any future environmental impact statements or regulatory analysis.
  • While the Forest Service appropriately analyzes costs and benefits from a global perspective, it also gives equal attention to national and forest-only perspectives, which are inappropriate in the context of climate change and inconsistent with uniform agency practices.
  • The Forest Service should adopt EPA’s Social Cost of Methane methodology, or at least use methane’s 20-year global warming potential and monetize carbon dioxide-equivalents in the main economic analysis. As the agency’s own sensitivity analysis reveals, the costs associated with methane are significant enough to flip some net present value calculations from positive to negative.
  • The Forest Service should abandon the assumption that all increased electricity from coal is perfectly offset by decreased electricity from other sources. This faulty assumption likely undercounts the net greenhouse gas emissions generated by this proposed action.
  • Finally, the Forest Service must reconsider, under the principles of Executive Order 12,866, whether the benefits of this deregulatory action justify the significant social costs. Similarly, given that the action’s social costs outweigh its benefits, and that the Forest Service has declined to study potential mitigation measures such as methane capture and carbon offsets, the Forest Service should reconsider whether it has fulfilled its mandate under the National Environmental Protection Act (NEPA).

Filed under Climate Change and Energy Policy, Natural Resources, Public Comments