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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />63 <br />is a measure of the benefit of reducing greenhouse gas emissions now and thereby avoiding <br />costs in the future.206 The charts below depict, (A) dramatically increasing damages from <br />global warming over time, as well as (B) the social cost of these carbon emissions based on <br />2013 TDS values.207 <br /> <br /> <br />Leading economic models all point in the same direction: that climate change causes <br />substantial economic harm, justifying immediate action to reduce emissions.208 The interagency <br />process to develop SCC estimates—originally described in the 2010 interagency technical <br />support document (“TSD”), and updated in 2013 and 2015—developed four values based on the <br />average SCC from three integrated assessment models (DICE, PAGE, and FUND), at discount <br />rates of 2.5, 3, and 5 percent,209 as well as a fourth value, which represents the 95th percentile <br /> <br />206 See Ruth Greenspan and Dianne Callan, More than Meets the Eye: The Social Cost of Carbon <br />in U.S Climate Policy, in Plain English, WORLD RESOURCES INSTITUTE (July 2011) (attached as <br />Exhibit 110). 207 See Richard Revesz, et al., Global warming: Improve economic models of climate change, <br />NATURE 508, 173-175 (April 10, 2014) (attached as Exhibit 111). 208 See id. at 174. 209 The choice of which discount rate to apply—translating future costs into current dollars—is <br />critical in calculating the social cost of carbon. The higher the discount rate, the less significant <br />future costs become, which shifts a greater burden to future generations based on the notion that <br />the world will be better able to make climate investments in the future. The underlying <br />assumption of applying a higher discount rate is that the economy is continually growing. The <br />IWG’s “central value” of three percent is consistent with this school of thought—that successive <br />generations will be increasingly wealthy and more able to carry the financial burden of climate <br />impacts. “The difficultly with this argument is that, as climate change science becomes <br />increasingly concerning, it becomes a weaker bet that future generations will be better off. If <br />they are not, lower or negative discount rates are justified.” WRI Report, at 9 (attached as <br />Exhibit 110). “Three percent values an environmental cost or benefit occurring 25 years in the <br />future at about half as much as the same benefit today.” Id.