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Comments on BOEM’s Environmental Impact Statement for the Proposed Cook Inlet Lease Sale 258

The Bureau of Ocean Energy Management (“BOEM”) recently released an environmental impact statement (“EIS”) for its proposal to lease more than one million acres of submerged land on the Alaska Outer Continental Shelf for oil and gas development. BOEM proposes to take this action despite estimating that it could lead to more than $1.3 billion in climate damages, and despite presenting no estimate of the economic benefits, against which these climate costs might be compared.

We submitted comments on the EIS, which begin by commending BOEM for taking the important step of considering climate impacts by monetizing greenhouse gas emissions using the social cost of greenhouse gases tool.  We then make recommendations for how BOEM can improve its decisionmaking with respect to the proposed action, including by:

  • Better incorporating the social cost values into its final determination by monetizing other important effects of the proposal and then comparing the overall costs and benefits;
  • Considering the informational value of delaying leasing, known as “option value”;
  • Correcting various errors in the agency’s economic model that cause it to underestimate the proposal’s emissions;
  • Applying the economic model consistently across impacts, rather than using it to offset the proposal’s environmental costs but not its economic benefits.