2020-06-24_REVISION - C1981035 (2)

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Submission# Organization/Agency Name Commenter Type Comment Comment Response as Exhibit 30.BLM has also utilized the social cost of carbon protocol in the context of oil and gas approvals.For example,the Billings Field Once estimated'the annual SCC[social cost of carbon]associated with potential development on lease sale parcels:'See Exhibit 31 to our previous comments.In conducting its analysis,the BLM used a"3 percent average discount rate and year 2020 values,"presuming social costs of carbon to be$46 Per metric ton.Based on its estimate of greenhouse gas emissions,the agency estimated total carbon costs to be"$38,499(in 2011 dollars)."In Idaho,the BLM also utilized the cial cost of carbon protocol to analyze and assess the costs of oil and gas leasing.Using a 3%average discount rate and year 2020 values,the agency estimated the cost of carbon to be$51 per ton of annual CO2e increase.See Exhibit 32 to our previous comments. Based on this estimate,the agency estimated that the total carbon cost of developing 25 wells on five lease parcels to be$3,689,442 annually.To be certain,the social cost of carbon protocol presents a conservative estimate of economic damages associated with the ental impacts climate change.As the EPA has noted,the protocol'does not environmn include all important[climate charge]tlamages."Exhibit 24 to previous comments. As rthe EPA explained:The models used to develop[social cost of carbon]estimates do not currently include all of the important physical,ecological,and economic impacts of climate change recognized in the climate change literature because of a lack of precise information on the nature of damages and because the science incorporated into these models naturally Iagsbehind the most recent research.In fact,more recent studies have reported significantly higher carbon costs.Forinstance,a report published in 2015 found that current estimates for the social cost of carbon should be increased six times for a mid-range value of$220 per ton.See Exhibit 33 to previous comments.A report from 2017,estimated carbon costs to be$50 per metric ton,a value that experts have found to be the"best estimate of the social cost of greenhouse gases."This report is attached as Exhibit 34.Vet,in spite of uncertain and likely underestimation of carbon costs by the IWG SCC,nevertheless,'the SCC is a useful measure to assess the benefits of CO2 reductions,'and thus a useful re to assess the costs of CO2 increases.See Exhibit 24 to previous comments The requirement to analyze the social cost of carbon is supported by the generalrequirements of NEPA and is specifically supported in federal case law.Courts have ordered agencies to ess the social cost of carbon pollution,even before a federal protocol for such analysis as atlopled.In 2008,the U.S.Court of Appeals forthe Ninth Circuit ordered the National Highway Traffic Safety Administration to include a monetized benefit for carbon emissions reductions in an Environmental Assessment prepared under NEPA.Center for Biological Diversity v.Nat'l Highway Traffic Safety Admin.,538 F.3d 1172,1203(9th Cir.2008).The Highway Traffic Safety Administration had proposed a rule setting corporate average fuel omy standards for light trucks.A number of states and public interest groupschallenged the rule for,among other things,failing to monetize the benefits that wmid accrue from a decision that led to lower carbon dioxide emissions.The Administration had monetized the employment and sales impacts of the proposed action. Id.at 1199.The agency argued,however,that valuing the costs of carbon emissions was oo uncertain.Id.at 1200.The court found this argument to be arbitrary and capricious.Id. The court noted that while estimates of the value of carbon emissions reductions occupied wide range of values,the correct value was certainly not zero.Id.It further noted that other benefits,while also uncertain,were monetized by the agency.Id.at 1202.In 2014,a federal court tlid likewise for a federally-approved coal lease.That court began its analysis by recognizing that a monetary cost-benefit analysis is not universally required byNEPA. See High Country Conservation Advocates v.U.S.Forest Sew.,52 F.Supp.3d 1174,1193 (D.Colo.2014)(citing 40 C.F.R.§1502.23).However,when an agency prepares a cost benefit analysis,It cannot be misleading:'Id.at 1182(citations omitted).In that case,the NEPA analysis included a quantification of benefits of the project,but,the quantification of the social cost of carbon,although included in earlier analyses,was omitted in the final NEPA analysis.Id.at 1196.The agencies then relied on the stated benefits of the project to NEPA project approval.This,the court explained,was arbitrary and capricious.Id.Such approval was basetl on s NEPA analysis with misleading economic assumptions,an approach long tlisallowed by courts throughout the country.Id.Furthermore,the court reasoned that even if the agency had decided that the social cost of carbon was irrelevant, the agency must still provide'Justifiable reasons for not using(or assigning minimal weight to)the social cost of carbon protocol...:.Itl.at 1193(emphasis added).In August 2017,a federal district court in Montana cited to theHigh Country decision and reaffirmed its ressoni rejecting a NEPA analysis for a coal mine expansion that touted the economic benefits of the expansion without assessing the carbon costs that would result from the tlevelopmant.See Mont.ErMI.Info.Ctr.v.U.S.OTfce of Surtace Mining,No.CV 15-106-M- DWM D.Mont.Au.14,2017.A 2015 0-ed in the New Vork Times from Michael B-14