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The federal government’s revised social cost of carbon figure is too low to adequately capture several social and economic harms posed by climate change, environmental groups said in a report released March 13. The $37 per metric ton figure that federal agencies use to calculate the impact of climate change in their regulations is either missing or improperly quantifying the threats posed by increased risk of high-ozone days, drought, ocean acidification, loss of species and habitat and other impacts, according to the report, “Omitted Damages: What’s Missing From the Social Cost of Carbon,” issued by the Institute for Policy Integrity, the Environmental Defense Fund and the Natural Resources Defense Council.

Carbon dioxide emissions are causing the climate to change and those changes come with a real cost. The big questions are what’s the price tag for that “social” cost and when does it gets paid? According to a new report, current best estimates could actually be on the low end thanks to “unknown unknowns.” The most recent estimate for the cost of a ton of carbon emissions — referred to as the social cost of carbon — is $37. That number was calculated in 2013 by 12 federal agencies using three models that incorporate both our physical understanding of climate change and the cost of climate impacts around the globe. The new report published March 13 argues that these estimates are far too low because they ignore or poorly quantify 29 key climate impacts. The Cost of Carbon Project, a partnership between the Institute for Policy Integrity, Environmental Defense Fund, and Natural Resources Defense Council, published the report.

The Obama administration’s controversial social cost of carbon underestimates the economic damage done by carbon dioxide emissions by ignoring some of warming’s effects on health and resource availability, according to a report released today by New York University’s Institute for Policy Integrity, the Natural Resources Defense Council and the Environmental Defense Fund. The paper seeks to refute industry allies’ charges that the Obama administration inflated costs when it revised the tally sharply upward last year. The estimate released last May put the SCC at $37 per ton of CO2, up from an estimated $24 a ton in 2010. “While some have questioned the increase in the SCC as too high, a thorough examination of the latest scientific and economic research shows that $37 should be viewed as a lower bound,” report author Peter Howard said. “This is because the studies available to estimate the SCC omit many climate impacts — effectively valuing them at zero.”

The U.S. government uses $37 as its estimate of how much a ton of carbon dioxide emitted into the atmosphere costs, including decreased agricultural productivity, damage from rising sea levels and harm to human health related to climate change. The Obama administration updated that figure, known as the “social cost of carbon,” in November. But a report released Thursday argues that $37 is far too low. It doesn’t include costs of other major climate impacts, such as increased respiratory illness from higher pollen or ozone, or the spread of insect-borne diseases such as Lyme disease, or the toll that ocean acidification will take on fisheries. The report comes from the environmental groups Natural Resources Defense Council and Environmental Defense Fund, and the Institute for Policy Integrity, based at New York University’s School of Law. Policy Integrity economic fellow Peter Howard authored the report, posted on the group’s website, Cost of Carbon.

Now with the clock winding down on the Obama administration, experts say it’s unclear whether EPA will craft carbon-emissions standards for any big stationary pollution sources beyond power plants—or even if it has enough time or resources left to do so. … When it comes to carbon emissions standards for big stationary industrial polluters, power plants are the big show—and maybe the only one. Michael Livermore of the Institute for Policy Integrity, an environmental group affiliated with New York University’s law school, said the fact that the clock is running out on emissions standards beyond power plants is a “concern.” But what’s crucial, he said, is for EPA to focus on creating carbon emissions standards for power plants that will withstand challenges in the courts and on Capitol Hill, and he noted that the power plant rules are a high priority for environmentalists. Those EPA rules are a centerpiece of President Obama’s climate agenda. “My guess is they see the refineries … as icing on the cake,” said Livermore, who was the founding executive director and is now senior adviser to the institute. “But they mostly want to make sure the cake doesn’t fall apart.”

The Heritage Foundation recently published a faulty report on the economic effects of the EPA’s forthcoming carbon pollution regulations, and its findings have been repeated uncritically in conservative media despite the foundation’s fossil fuel funding and the report’s “deeply problematic” analysis. Michael Livermore, Senior Advisor at New York University’s Institute for Policy Integrity, explained in a phone call that “even as a cost prediction, [the report is] very inaccurate because it doesn’t paint a complete picture about how the economy is going to respond.”

The Obama administration relied on outdated science that produced a social cost of carbon figure that is too conservative, environmental groups said Feb. 26. “This estimate should be regarded as the lower bound on the true number,” Richard Revesz, director of the Institute for Policy Integrity at the New York University School of Law, told reporters. The Institute for Policy Integrity, Environmental Defense Fund and Natural Resources Defense Council announced Feb. 26 that they had launched a new website, http://costofcarbon.org/, to collect academic research on the social cost of carbon figure. The first report on damages not being accounted for in the federal government’s estimate is expected in March, Revesz said.

Richard Revesz, director of the Institute for Policy Integrity at the New York University School of Law, discusses the arguments and potential outcomes in the Supreme Court case on the ability of EPA to regulate greenhouse gases under the Clean Air Act. He also explains its significance in the context of the broader discussion on EPA’s ability to regulate greenhouse gas emissions.

President Obama’s use of executive power to tackle global warming goes on trial Monday when the Supreme Court hears arguments in a challenge from industry and a dozen states to an EPA effort to curb industrial emissions of greenhouse gases. The program at the heart of the case — prevention of significant deterioration, or PSD — requires facilities to obtain permits that mandate the use of “best available” control technology to limit emissions. EPA supporters say the agency has long said regulating new pollutants under other parts of the Clean Air Act requires inclusion in the PSD program. “For 30 years, EPA has had a consistent approach to this program,” said Richard Revesz, director of the New York University School of Law’s Institute for Policy Integrity.

The Institute for Public Integrity, based at New York University, filed a friend-of-the-court, or amicus, brief this morning, saying EPA’s treatment of carbon dioxide as a pollutant does not violate the Clean Air Act. The group asserted that the EPA was right to give carbon dioxide equal weight to other pollutants in the agency’s first greenhouse gas regulations, rules that are being challenged in the U.S. Supreme Court by a coalition of utilities, manufacturers and business groups. The last 30 years of regulation and statutory amendments show that Congress intended the agency to manage all regulated pollutants, not just ones that affect local air quality, states the brief. “The truth of the matter is that EPA’s position has been consistent for 30 years,” said Richard Revesz, faculty director at Policy Integrity.