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Comments on the Social Cost of Carbon in Metal Halide Lamp Fixtures Rule

Policy Integrity, along with the Environmental Defense Fund, the Natural Resources Defense Council, and the Union of Concerned Scientists, submitted comments on the social cost of carbon. The calculation—an estimate of the damage caused by each ton of carbon emissions—was used in a rule proposed by the Department of Energy regarding energy conservation from metal halide lamp fixtures. The joint comments show that according to cutting-edge economic research, the estimate used by the government may be too low.

The group also submitted comments on a petition for correction filed by industry groups to the Office of Management and Budget (OMB) and other agencies. The industry groups’ request to prohibit the use of the social cost of carbon is based on erroneous arguments and our comments urge the OMB to deny the petition. We find that the government used the proper models and statistical methodologies to estimate damages of climate change and the benefits of emission reduction.

In 2011, Policy Integrity along with five other organizations sent a letter to senior U.S. government officials urging the Administration to fulfill its commitment to update the SCC to reflect improving science and economic understanding of climate change and its impact.