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Comments on Use of the Social Cost of Greenhouse Gases in Environmental Impact Statements

We recently submitted joint comments to advocate for the proper use of the social cost of greenhouse gases in multiple environmental impact statements.

Our comments to the Office of Surface Mining and Reclamation (OSMRE) and our comments to the Bureau of Land Management (BLM) focused on the agencies’ failure to use the social cost of greenhouse gases metric to account for the climate effects of anticipated project emissions. As we have argued in past comments on environmental impact statements, we explain that NEPA requires a rigorous assessment of climate impacts, and that the social cost of greenhouse gases metric is appropriate for monetizing the effects of project-level emissions, like those discussed in these EISs. We also emphasize that the 2016 Interagency Working Group estimates of the social cost of greenhouse gases remains the best available. Both OSMRE and BLM also failed to discuss how the projects, the expansion of a coal mine and drilling of additional oil and gas wells, respectively, could increase downstream greenhouse gas emissions.

In our comments on the Bureau of Ocean Energy Management (BOEM)’s 5-year scoping plan for offshore oil and gas leasing, we emphasized that if and when BOEM decides to monetize greenhouse gas emissions, it should use the 2016 IWG estimates, as it has done in the past.