Earlier this year, the Council of Environmental Quality (CEQ) published interim guidance on analyzing climate change effects under the National Environmental Policy Act in which it endorsed using the social cost of carbon in environmental analysis. In this supplemental comment letter, we suggest that CEQ specifically endorse the Environmental Protection Agency’s newly-updated climate-damage values when it finalizes the interim guidance. As our letter explains, EPA’s updated values are the most robust and comprehensive federal climate-damage estimates currently available.
This comment builds off a more comprehensive comment letter that we filed on the interim guidance in April 2023.