cover image: Comment Submitted To The State of Montana Public Service Commission

20.500.12592/31zcxtx

Comment Submitted To The State of Montana Public Service Commission

5 Apr 2024

It is driven by RCP8.5, a GHG concentration scenario virtually impossible. It is estimated using climate models that overstate the actual atmospheric temperature record by a factor of 2.3. It includes the purported global impacts of increasing atmospheric concentrations of GHG, an incorrect methodological approach because most such effects, whether consistent with the evidence or not, will be borne by individuals not residing with the U.S., and thus essentially unaffected by U.S. policies because the climate effects of U.S. GHG emissions are either very small or effectively zero, and because the inclusion of global damages in the analysis of U.S. policies would create a very large distortion in terms of the efficient international adoption of climate policies. It ignores the large uninternalized social benefits of rising GHG concentrations and 3 moderate warming. It includes the asserted “co-benefits” of reduced emissions of criteria and hazardous air pollutants as central components of the benefits of GHG reductions, a blatant exercise in double-counting. It employs artificially low discount rates, a methodology that would distort resource allocation during the current time period and across time periods, and that would make future generations unambiguously poorer. It mischaracterizes the GDP effects of rising GHG concentrations as projected in the central integrated assessment models.
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Authors

Benjamin Zycher

Published in
United States of America