Summary:

A number of comments on the BOEM proposed OCS leasing program oppose the proposal on “climate” grounds, that is, on the purported adverse effects of the greenhouse gas emissions that would result from the fossil energy production attendant upon the expanded leasing of OCS federal lands for such production.

That general stance cannot withstand scrutiny. The proposed leasing program, under highly conservative assumptions, would increase aggregate GHG emissions by about 280 million metric tons per year, yielding a temperature impact by 2100 of 0.0082°C, as predicted by the Environmental Protection Agency climate model. Any such impact — effectively zero — should not affect choices among policy outcomes. Even this impact assumes away any production decreases elsewhere in the world engendered by the proposed leasing program and attendant future increase in U.S. fossil energy output.

The annual value of the future fossil energy output to be engendered by the proposed leasing program might be about $3.6 billion. Opposition to the proposed leasing program based upon “climate” concerns must assume a social cost of GHG (SC-GHG) of at least $120 per ton, a figure deeply dubious on analytic grounds, in particular because of the use of artificially-low discount rates.

The available body of evidence does not support the ubiquitous assertions that a climate “crisis” is upon us or looming large. Accordingly, policy-driven limitations on OCS leasing and oil and gas production would impose a reduction in national wealth upon the U.S. economy literally without any compensating improvements in environmental quality. Opposition to the proposed leasing program based upon a “climate” or GHG emissions rationale cannot be supported analytically. BOEM should not take such arguments into account when considering a finalization of its proposed leasing program.

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