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Comments to BLM on Big Papi Application to Drill

We submitted joint comments on BLM’s environmental assessment for the Big Papi project. In the EA, BLM recycles the main Trump-era arguments that agencies used to justify their decision not to apply the social cost of greenhouse gases. In these comments, we draw BLM’s attention the proposed action's significant climate damages, amounting to between $114 million and $161 million over the lifetime of the planned wells. We also explain why the social cost metric is appropriate for use in the NEPA context, that the Interagency Working Group’s estimates are designed for measuring climate damages caused by a marginal addition of greenhouse gases to the atmosphere, and why uncertainty is no reason to abandon the social cost estimates.