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Comments On the Social Cost of Carbon in DOE’s Refrigerator Rule

Policy Integrity, along with Environmental Defense Fund, Natural Resources Defense Council, and Union of Concerned Scientists, submitted comments on the social cost of carbon (SCC) within a rule proposed by the Department of Energy regarding energy conservation for commercial refrigeration equipment. The 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.

Our comments support DOE’s use of the government SCC measure and the transparency of the process. The group also noted that current SCC values are likely underestimates and that this should be addressed in future updates.

On Oct 21, 2013, Policy Integrity, along with the above organizations, submitted similar comments to DOE on the SCC regarding energy conservation from metal halide lamp fixtures. The comments said that economic research shows the estimate used by the government may be too low. In addition, the group submitted comments on a petition for correction filed by industry groups to the Office of Management and Budget (OMB) and other agencies. The group urged the OMB to deny industry groups’ request to prohibit use of the social cost of carbon. The comments said the industry groups’ petition is based on erroneous arguments and that the government used proper models and statistical methodologies.

Prior to that, 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.