Public Comment To DEQ MEPA Working Group 4.15.24

"If this really is a climate emergency, like some suggest, then we should be doing everything in our power to streamline our permitting process, NOT implementing more red tape on projects that will ultimately benefit the climate."

April 15th, 2024
RE: DEQ MEPA WORKGROUP: SUBTASK GROUP ON CLIMATE ANALYSIS

Dear Members of MEPA Workgroup, 

Today, I wanted to discuss two reasons why it is incumbent upon you to reject both a MEPA Social Cost of Carbon analysis and an emissions analysis based on any Scope, but especially Scope 2 and 3.

• MEPA is unequivocally a procedural law. Applying a Social Cost of Carbon analysis or Scope Analysis to MEPA would NOT reduce emissions, NOR would it make it easier for environmentally friendly projects to get built. It would merely add another layer of uncertainty that would increase project delays and fuel litigation.

• These highly controversial and easily manipulatable analyses would require Montana to defer to the federal government. We should NOT be ceding Montana’s authority to set our own climate policy to the federal government bureaucracy. We need to protect our own state’s sovereignty, not offering it up on a golden platter to DC bureaucrats.

The fact is that often the biggest barrier climate-friendly projects face are ambiguous rules and uncertain outcomes resulting from the environmental permitting process. If this really is a climate emergency, like some suggest, then we should be doing everything in our power to streamline our permitting process, NOT implementing more red tape on projects that will ultimately benefit the climate. 

Thank you,
Tanner Avery