Abstract
Pending either legislative action or formal agency guidance, utilization of the Social Cost of Carbon in analyses of energy development projects on federal land under the National Environmental Policy Act (NEPA) is not required. However, current trends indicate that future NEPA documentation of proposed energy projects on federal land will likely address and discuss project impacts on climate change using increasingly quantitative metrics. Accordingly, parties should be prepared to offer substantive comments on the suitability and accuracy of quantitative analyses of the impacts associated with greenhouse gas emissions and offer suggestions for meaningful mitigation measures to reduce such estimates.
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