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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 64 SCC estimate across all three models at a 3 percent discount rate, and demonstrates the cost of worst-case impacts.210 These models are intended to quantify damages, including health impacts, economic dislocation, agricultural changes, and other effects that climate change can impose on humanity. While these values are inherently speculative, a recent GAO report has confirmed the soundness of the methodology in which the IWG’s SCC estimates were developed, therefore further underscoring the importance of integrating SCC analysis into the agency’s decisionmaking process.211 In fact, certain types of damages remain either unaccounted for or poorly quantified in IWG’s estimates, suggesting that the SCC values are conservative and should be viewed as a lower bound.212 The updated interagency SCC estimates for 2020 are $12, $42, $62 and $123 per ton of CO2 (in 2007$).213 The IWG does not instruct federal agencies which discount rate to use, suggesting that the 3 percent discount rate ($42 per ton of CO2) as the “central value,” but further emphasizing “the importance and value of including all four SCC values[;]” i.e., that the agency should use the range of values in developing NEPA alternatives.214 In 2014, the district court for the District of Colorado faulted the Forest Service for failing to calculate the social cost of carbon, refusing to accept the agency’s explanation that such a calculation was not feasible. High Country Conservation Advocates v. U.S. Forest Service, 52 F.Supp.3d 1174 (D.Colo. 2014) (a decision the agency decided not to appeal, thus implicitly recognizing the importance of incorporating a social cost of carbon analysis into NEPA decisionmaking). Notably, the High Country Conservation Advocates decision applies to the same geographic area (the North Fork Valley), and to the same coal field (the Somerset), that is at issue here. In his decision, Judge Jackson identified the IWG’s SCC protocol as a tool to “quantify a project’s contribution to costs associated with global climate change.” Id. at 1190.215 To fulfill this mandate, they agency must disclose the “ecological[,] … economic, 210 See 2013 TSD at 2 (attached as Exhibit 109). 211 GAO-14-663, Social Cost of Carbon (July 24, 2014). 212 See Peter Howard, et al., Omitted Damages: What’s Missing From the Social Cost of Carbon, ENVIRONMENTAL DEFENSE FUND, INSTITUTE FOR POLICY INTEGRITY, NATURAL RESOURCES DEFENSE COUNCIL (March 13, 2014) (attached as Exhibit 112) (providing, for example, that damages such as “increases in forced migration, social and political conflict, and violence; weather variability and extreme weather events; and declining growth rates” are either missing or poorly quantified in SCC models). 213 See 2013 TSD (July 2015 Revision) at 3 (attached as Exhibit 109) (including a table of revised SCC estimates from 2010-2050). To put these figures in perspective, in 2009 the British government used a range of $41-$124 per ton of CO2, with a central value of $85 (during the same period, the 2010 TSD used a central value of $21). WRI Report at 4 (attached as Exhibit 110). The UK analysis used very different assumptions on damages, including a much lower discount rate of 1.4%. The central value supports regulation four times a stringent as the U.S. central value. Id. 214 See 2013 TSD at 12 (attached as Exhibit 109). 215 See also id. at 18 (noting the EPA recommendation to “explore other means to characterize the impact of GHG emissions, including an estimate of the ‘social cost of carbon’ associated with potential increases in GHG emissions.”) (citing Sarah E. Light, NEPA’s Footprint: Information Disclosure as a Quasi-Carbon Tax on Agencies, 87 Tul. L. Rev. 511, 546 (Feb. 2013)).