Resources

  • Analytical Clarity: How Updated Climate-Damage Values and Discount Rates Will Affect Regulatory Analysis

    Recently completed and draft guidance is ushering in updated practices for federal benefit-cost analysis. This policy brief examines the impact of two of the most significant upcoming changes: to the discount rate and the social cost of greenhouse gases.

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  • The Social Cost of Carbon: Options for Applying a Metric in Flux

    Many states and other jurisdictions are grappling with how to value greenhouse gas emission reductions and trying to understand the rapidly developing climate economics and science involved in this task. Frequently, state governments and other jurisdictions value greenhouse gas emissions in policymaking using a tool known as the social cost of carbon. While applying the social cost of carbon is conceptually simple, the appropriate value to place on the metric is in flux. In late 2022, the federal government released new, updated values of the social cost of carbon in draft form which, for now, remain unfinalized. So what estimates of the social cost of carbon should states and other entities use during this transition period? This policy brief explores the available options.

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  • Comments to the Michigan Public Service Commission on DTE and Consumers Energy’s Proposal for a Benefit Cost Analysis Test

    In 2022, as part of a multi-year MI Power Grid Initiative initiative focused on maximizing the benefits of the transition to clean, distributed energy resources, the Michigan Public Service Commission (PSC) directed specified Michigan electric utilities to file a proposal for a benefit-cost analysis (BCA) framework for use in evaluating prospective pilot programs.  In February 2023, DTE Electric Company and Consumers Energy filed a BCA proposal, and on June 23, Policy Integrity submitted comments to the PSC on that proposal. Our comments made several recommendations to ensure that the BCA framework would be useful for properly weighting environmental impacts associated with proposed pilots and maximizing net benefits, including that the test ultimately adopted should incorporate Michigan’s decarbonization policy with greater specificity.

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  • Comments on EPA Draft Update to Social Cost of Greenhouse Gas Metrics

    The Institute for Policy Integrity at NYU School of Law and a coalition of environmental groups submitted comments to the U.S. Environmental Protection Agency (EPA) on its draft update to the social cost of greenhouse gas estimates of climate damage. The comments commended the agency’s extraordinary advances and recommended ways to further improve the accuracy of the metrics.

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  • EPA Proposes Draft Updates for Social Cost of Greenhouse Gas Metrics

    In November 2022, the U.S. Environmental Protection Agency (EPA) announced the release of draft updated values for the social cost of greenhouse gas metrics. These metrics, which quantify the expected economic damages caused by greenhouse gas emissions, are used to evaluate the costs and benefits of climate-related regulations and other policy decisions. The social cost of carbon’s central value was updated from $51-per-ton to $190 (for emissions in 2020), consistent with similar trends in the economics literature.

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  • The Social Cost of Greenhouse Gases: A Guide for State Officials

    As states step up on climate action, they need a way to weigh climate goals against other policy objectives. The social cost of greenhouse gases (SC-GHG) can help policymakers understand the costs and benefits of climate action and inaction. This new guide for state officials explains why the SC-GHG is a useful policy tool and how it can be applied.

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  • Comments Supporting the Widespread Usage and Recommending Updates to the Social Cost of Greenhouse Gases (Docket No. OMB-2021- 0006-0001)

    Earlier this year, the Biden administration reestablished the Interagency Working Group on the Social Cost of Greenhouse Gases. Its first move was to discard the Trump administration’s flawed social cost values, which significantly understated the per-ton climate damages of greenhouse gas emissions. The Working Group published interim values, based on Obama-era estimates, and is now working to revise those values by January 2022 to incorporate the latest science and economics.

    In addition to our own comment letter and reports, Policy Integrity collaborated with nine partner organizations to submit joint comments that, among other recommendations, encourage the Working Group to:

    -endorse the broad application of the social cost of greenhouse gas values in all relevant decisions and processes;
    -bolster the justifications for focusing on global damage estimates; and
    -apply lower discount rates below the current range

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  • Policy Integrity Comments to the Office of Management and Budget on the Social Cost of Greenhouse Gases

    Earlier this year, the Biden administration reestablished the Interagency Working Group on the Social Cost of Greenhouse Gases. Its first move was to discard the Trump administration’s flawed social cost values, which significantly understated the per-ton climate damages of greenhouse gas emissions. The Working Group published interim values, based on Obama-era estimates, and is now working to revise those values by January 2022 to incorporate the latest science and economics.

    As part of its process for revising the social cost of greenhouse gas values, the Working Group requested public input. We published and submitted five original reports on key issues, as well as a comment letter that summarizes the reports and offers several additional points for the Working Group’s consideration.

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  • Playing with Fire: Responding to Criticism of the Social Cost of Greenhouse Gases

    Federal agencies will need to offer considered and detailed responses to objections raised in the notice-and-comment processes for individual regulations or administrative actions that apply the Working Group’s social cost valuations. The Working Group should consider providing such responses now, and our report offers a blueprint for responding to objections being raised by opponents of climate regulation.

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  • Expert Elicitation and the Social Cost of Greenhouse Gases

    Researchers often formally elicit the views of subject-matter experts to help clarify consensus on complex or uncertain topics. Our report highlights several updates, incorporating data from expert elicitations, that the Working Group should consider as it works to improve the social cost of greenhouse gases.

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