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Comments on BLM’s Failure to Monetize Greenhouse Gas Emissions (Riley Ridge and Greater Mooses EISs)

We recently submitted two sets of joint comments to the Bureau of Land Management on the agency’s failure to monetize the climate effects of two fossil fuel projects in their NEPA analyses. One project, Riley Ridge to Natrona project, includes an underground carbon dioxide pipeline and accompanying facilities. In BLM’s environmental impact statement (EIS) for Riley Ridge, the agency incorrectly claims, citing an EIS produced by the Federal Energy Regulatory Commission, that it is not possible to attribute discrete environmental impacts to greenhouse gas emissions. We explain in our comments that not only is the social cost of greenhouse gases metric designed to attribute significance to discrete amounts of emissions, but a thorough and meaningful discussion of a project’s climate impacts is required by NEPA.

In the Greater Mooses Tooth draft supplemental EIS, BLM makes a number of faulty arguments for not using the social cost of greenhouse gases, which we address in our comments. First, BLM cites the disbanding of the federal Interagency Working Group on the Social Cost of Greenhouse Gases (IWG) as a reason for not using the IWG’s estimates. Second, BLM cites disagreement over the choice of discount rate for calculating the social cost of greenhouse gases as a reason to forego applying the metric. Third, BLM cites the Electric Power Research Institute’s critiques of the IWG’s methodology as proof that the tool is flawed, in particular taking issue with the three integrated assessment models. Fourth, BLM falsely claims that the social cost of greenhouse gases “does not measure the actual incremental impacts of a project,” even though the social cost of greenhouse gases was precisely designed to do just that. Fifth, BLM says that because the social cost of greenhouse gases does not take into account “all damages or benefits from carbon emissions” or the “social benefits of energy production,” using the global social cost of greenhouse gases estimates “would be unbalanced and of limited use to the decision-maker.”

Our joint comments explain why each of BLM’s reasons for not using the social cost of greenhouse gases in these NEPA assessments fails, and how the agency leaves the public and decisionmakers in the dark about the climate effects of the project, in violation of NEPA.