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Comments to the Forest Service on Quantifying and Monetizing Greenhouse Gas Emissions

We recently submitted comments to the United States Forest Service on a Draft Environmental Impact Statement (EIS) that makes problematic claims about evaluating greenhouse gas emissions. In the Pine Mountain Late-Successional Reserve Habitat Protection and Enhancement Project Draft EIS, the Forest Service gives three main reasons for not quantifying—or monetizing the effects of—greenhouse gas emissions from the proposed action. First, the Service claims that “project level emissions alone are not sufficient to cause climate change.” Second, the Service claims that the “large majority of Forest Service projects” are too “small” for it to be “presently possible to conduct quantitative analysis of actual climate change effects.” Finally, the Service questions whether “such disclosure would provide a practical or meaningful effects analysis for project decisions.” We explain why each of these reasons is wrong according to economic principles, the requirements of the National Environmental Policy Act, and the Service’s own guidance regarding climate change.

We recommend that when the Service finalizes the Pine Mountain EIS, it abandon these inaccurate and misleading over-generalizations regarding the climate effects of individual projects. Instead, we urge the Service to rationally apply its judgment to the evidence to answer whether this specific project’s greenhouse gas emissions are most likely too small to warrant quantification, such that the informational benefit of quantification does not justify the expense of quantification. If the Service finds the project will likely have significant greenhouse gas effects, we stress that the Service must quantify those effects to the extent feasible, and should further monetize those effects using the social cost of greenhouse gas metrics.