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Letter to Senior Government Officials on Social Cost of Carbon Presentation

Today, Policy Integrity, with five national environmental organizations offered to senior officials in the Obama Administration recommendations on how the social cost of carbon (SCC) should be presented in greenhouse gas regulations.

At issue is the difficulty in quantifying the full range of damages from climate change and to incorporate catastrophic risks when placing a monetary value on what is lost when a ton of greenhouse gases are released into the atmosphere. Because of this challenge and because the model outputs is sensitive to a range of underlying assumptions, agencies should include additional materiasl in their presentation of the SCC.

The letter, sent to the heads of the Department of Energy, Environmental Protection Agency and twelve others, asked that the climate impacts omitted from the models be identified explicitly; that SCC values be presented as a distribution, rather than simple point estimates such as means or medians; and that a comprehensive discussion of model assumptions and their implications be provided.

These as well as a recommendation that the SCC estimates be presented and updated as part of an ongoing assessment would ensure that the unquantifiable nature of the social cost of carbon be taken into consideration.