The U.S. District Court for the Northern District of California vacated the Bureau of Land Management's repeal of an Obama-era rule that was designed to reduce wasteful venting of methane from natural gas operations on federal lands. The court ruled in part that it was arbitrary for the Trump Administration to have reduced the estimate of the social cost of methane from $1300 per ton down to just $176 per ton by excluding from consideration any climate effect occurring outside U.S. borders. Policy Integrity has worked for years to build the case against the so-called “domestic-only” estimate of climate costs.
We’ve argued in public comments, academic articles, and reports that the “domestic-only” estimates in fact fail to consider the climate costs to U.S. businesses that own assets or trade outside our borders, to U.S. citizens and military that live and work outside our borders, to effects like climate-induced migration that will spill back across our borders, and to geopolitical security. These arguments comprised our amicus brief in the Northern District of California—and ultimately made their way into the court’s recent ruling. Now, all federal agencies should be on notice that their deregulatory efforts that rely on an arbitrary “domestic-only” estimate of climate costs—including the repeal of the motor vehicle efficiency standards—are legally vulnerable.