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Comments on Petition for Correction on Social Cost of Carbon

Policy Integrity, along with the Environmental Defense Fund, the Natural Resources Defense Council, and the Union of Concerned Scientists submitted comments opposing a petition for correction sent to the Office of Management and Budget (OMB) and the other agencies involved in the Interagency Working Group on the Social Cost of Carbon (IWG).

The social cost of carbon (SCC) calculation is an estimate of the damage caused by each ton of carbon emissions and used in the cost-benefit analyses of regulations with greenhouse gas emissions reductions.

The petition for correction seeks to stop government agencies from using the IWG’s 2010 and 2013 SCC estimates. In our comments we explain why the petitioners’ arguments are wrong and why they should be dismissed. We also argue that the SCC is in fact likely to be significantly underestimated, rather than inflated, as the petitioners claim.

We also sent comments to the OMB stating that the IWG has properly and lawfully used the leading models and well-established statistical methodologies to estimate the damages of climate impacts and the benefits of reducing carbon emissions. The current calculation is the best available and it is in the best interest of the public for agencies to use it until a better version is adopted.

Policy Integrity has been studying the social cost of cost since we began in 2008. While we believe it is best to use the current estimate, we have sent several letters over the years to senior U.S. government officials, as well as the President, urging the Administration to update the SCC to reflect improving science and economic understanding of climate change and its impact.