Public Interest Comment on The Interagency Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis under Executive Order No. 12866

February 26, 2014

Download this Public Interest Comment (PDF)


Introduction

In May 2013, the White House released a revised Technical Support Document (TSD) with a new estimate of the “social cost of carbon” (SCC), to be used by various agencies when evaluating the benefits of emissions regulations, energy efficiency standards, renewable fuel mandates, technology subsidies, and other policies intended to mitigate global warming.  Federal agencies immediately began using the revised SCC to make regulatory decisions, prompting objections from the public and requests for an opportunity to comment on the SCC and the underlying models and analyses.  On November 1, 2013, the White House released updated values for the SCC, and on November 26 invited the public to comment.  In this public interest comment we make four points:

First, we endorse the administration’s effort to arrive at a uniform SCC, to help ensure at least internal consistency across a portfolio of policies directed at reducing carbon emissions.

Second, we applaud the Office of Management and Budget’s (OMB’s) effort to seek public comment on the TSD, and urge the administration to follow through with scientific peer review and with other measures to ensure transparency in regulatory decisions.

Third, we caution that the task of estimating the SCC was undertaken with an apparent bias that needs to be corrected before it can be taken as objective.

Finally, we point out that the logical next step is not, contrary to the subtitle of the TSD, for regulatory agencies to incorporate the SCC into Regulatory Impact Analyses (RIAs).  Rather, the next step is to seek an international consensus on the value of the SCC and to negotiate a coordinated global policy response, which is the only way that the theoretical benefits of government actions to reduce global carbon emissions can be translated into actual results.