If constructed, the Atlantic Coast Pipeline Project would be responsible for greenhouse gas emissions resulting in over $1.3 billion per year of climate damages. The Federal Energy Regulatory Commission’s (FERC) analysis estimates the quantity of the project’s emissions but does not analyze the context, intensity, or significance of the incremental climate damages they will cause. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to monetize the project’s climate damages using Social Cost of Carbon (SCC) estimates is arbitrary.
When approving the Atlantic Coast Pipeline, FERC refused to conduct a more meaningful analysis based on a claim that there is no suitable method to do so. As our brief explains, however, the Social Cost of Carbon is a widely-accepted tool for calculating, in a common metric of dollars, the climate damages from an amount of greenhouse gas emissions. These monetized damages can then be used to determine the significance of those emissions. Our brief also explains that FERC’s reasons for refusing to use the Social Cost of Carbon are inconsistent with the consensus of experts and its own choice to monetize other effects. Given the availability of SCC estimates, FERC’s failure to contextualize and assess the pipeline’s climate impacts is arbitrary.