When Kayley Shoup, a community organizer with the Carlsbad-based group Citizens Caring for the Future, read over an environmental assessment for new oil wells and infrastructure near Loving, she noticed that the Bureau of Land Management chose not to analyze the social cost of carbon.
The BLM states in the environmental assessment that evaluating the social cost of carbon was not required under the National Environmental Policy Act and could provide inaccurate information because a full cost-benefit analysis was not conducted.
A social cost of carbon analysis looks at how the emissions from projects can impact human health and the environment.
Nathan Matthews, a senior attorney with the Sierra Club, described it as an estimate that federal agencies use to inform their decision making about the consequences of a project. He said it helps the federal agencies evaluate when the emissions from a project will create problems, when these emissions might occur and how much work would be needed to reduce the emissions from the project.
He said there is a formula the agencies can use to evaluate the social costs of carbon and that it is not a difficult process.
Completing the social cost of carbon analysis is also a way that the agencies can inform the public about the impacts of a project, Matthews said.
The BLM released the environmental assessment for public comment on Sept. 10 and will accept comments through Oct. 12.
The proposal includes a 400-acre lease in Eddy County and a waiver of a no surface occupancy lease stipulation for the Pecos River/Canyon Complex. The waiver is because the location of the lease parcel does not include any areas within the Pecos River/Canyon Complex Area of Critical Environmental Concern. When the parcel was nominated for leasing, the BLM states in the environmental assessment that the no surface occupancy stipulation was erroneously attached.
Emissions impact communities
The Loving project includes six new wells located on two pads, a battery tank, buried flowlines, access roads and power line extensions.
“It really is a big, big operation,” Shoup said.
Shoup said the emissions have led to a high rate of asthma and that she has been concerned by the number of people being diagnosed with lung cancer who live near well sites. At the same time, the pollution from the extractive industries has not been well studied in the Permian Basin and there are few air monitoring stations. Eddy County, for example, has a single station to monitor air quality, she said.
The environmental assessment acknowledges that the project could impact air quality in the Loving area, where ozone pollution is already pushing the federal attainment levels of 0.7 parts per billion. The ozone levels in Eddy County are at 0.68 parts per billion.
“We don’t need any more wells,” Shoup said.
She said on any given day she can take an optical gas imaging camera out into the basin and see up to six major emission events. These emissions contribute to climate change.
Shoup acknowledged the project could have economic benefits for the region, including job creation. But not everyone welcomes the oil boom economics. She said people flooding into the area for jobs in the oil field leads to increased cost of living and struggles finding housing, including places for teachers to live.
Reasons why social cost of carbon analysis was not done
In the environmental assessment, the BLM provided several reasons why the social cost of carbon analysis was not done.
“Most notably, this action is not a rulemaking for which the SCC protocol was originally developed,” the document states.
The BLM further highlights that in 2017, President Donald Trump issued an executive order that withdrew the technical support documents on which the social cost of carbon formula was based and disbanded the Interagency Working Group on Social Cost of Greenhouse Gases. This working group was created in 2009 by President Barack Obama and developed the formula that is now used to evaluate the social cost of carbon.
“Without a complete monetary cost-benefit analysis, which would include the social benefits of the proposed action to society as a whole and other potential positive benefits, inclusion solely of an SCC cost analysis would be unbalanced, potentially inaccurate, and not useful in facilitating an authorized officer’s decision,” the assessment states.
Matthews disagreed with that statement and said the Sierra Club has won court cases on the legal argument that even when cost-benefit analyses are not completed, agencies must still at least examine the social cost of carbon.
“Even if they do not like it, they may have to use social cost of carbon unless they can come up with a better way to analyze impacts,” he said. “So they can’t say ‘we don’t like social cost of carbon so therefore we’re going to be silent.’”
Finally, the environmental assessment states that “the full social benefits of carbon-based energy production have not been monetized and quantifying only the costs of [greenhouse gas] emissions but not the benefits would yield information that is both potentially inaccurate and not useful.”
The decision not to analyze the social cost of carbon comes in contrast to a secretarial order issued by U.S. Department of the Interior Secretary Deb Haaland in April that prioritized analysis of social costs of greenhouse gas emissions in decision making.
This order is one reason advocates say the social cost of carbon should have been completed.
Matthews said environmental advocates like Sierra Club are not alone in urging agencies to evaluate the social cost of carbon. He said even other federal agencies, like the U.S. Environmental Protection Agency, have been filing comments in dockets encouraging the use of the social cost of carbon analysis.
At the same time, he said there are instances when the social cost of carbon analysis would not be needed. For example, he said if greenhouse gas emission reduction targets have been developed, the agency can say whether the project is consistent with hitting those targets or not without using the social cost of carbon formula.
He said the BLM is in the process of exploring an agency-wide emissions budget, which could provide a different framework for evaluating greenhouse gas emissions.
“I don’t think social cost of carbon is the only way to talk about greenhouse gases,” he said.