Comments
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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 -
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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Joint Comments to EPA on Climate Effects from Cross-State Air Pollution Rule
In its proposal, Revised Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS, the Environmental Protection Agency’s (EPA) unreasonably low valuation of climate effects contributes to its selection of an inefficient policy alternative. Policy Integrity submitted joint comments detailing how EPA’s flawed analysis harms public health and the environment.
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Policy Integrity Comments to New York on the Value of Carbon
New York’s landmark climate bill, the Climate Leadership and Community Protection Act, requires the New York State Department of Conservation (DEC) to adopt a value of carbon. In October 2020, DEC published draft guidance for New York State agencies on what value of carbon to use, focusing on the IWG’s 2016 Social Cost of Carbon estimates. Policy Integrity submitted comments supporting DEC’s decision to use a damage-cost approach and demonstrating why a 2% discount rate is an appropriate central discount rate for New York’s value of carbon estimates. Policy Integrity’s comments also address how DEC should address co-benefits, unquantified benefits, and distribution effects of policies and programs with greenhouse gas effects. Finally, the comments discuss several considerations and guiding questions for DEC if it chooses to move forward with a marginal abatement cost approach.
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Joint Comments to EPA on Airplane GHG Emissions Regulations
The Environmental Protection Agency (EPA) proposed airplane pollution standards that have no effect on emissions and require no technological improvements. EPA does analyze one scenario in the technical support for the proposal, however, that appears to have modest greenhouse gas emissions reduction effects. But the agency improperly monetizes and weighs those reductions. Policy Integrity submitted joint comments that detail flaws in EPA’s analysis and describe how the agency can correctly apply the social cost of carbon.
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Policy Integrity Comments to Arizona on Integrated Resource Planning
The Arizona Corporation Commission regularly requires that load serving entities (LSEs), which supply electricity to ratepayers, file plans with a 15-year time horizon disclosing environmental impacts from different resource mixes and how they will address those impacts. Policy Integrity’s comments encourage the Commission to ask that LSEs provide monetized estimates of the damages they expect to result from greenhouse gas emissions using the social cost of carbon.
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Policy Integrity Comments to New Jersey on Cost Test Straw Proposal
The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. Policy Integrity’s comments encourage BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. The comments also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal.
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Policy Integrity Comments to Oregon PUC on the Social Cost of Carbon
Oregon Governor Kate Brown signed an executive order directing state agencies, including the Public Utilities Commission (PUC), to reduce greenhouse gas emissions. Policy Integrity submitted comments encouraging the PUC to use Social Cost of Carbon metrics to monetize the benefits of avoided greenhouse gas emissions.
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Comments to Rhode Island on Carbon Pricing Study
Rhode Island is undertaking a study to understand what a state carbon pricing scheme would look like and how it would interact with the state’s participation in the Regional Greenhouse Gas Initiative and the Transportation and Climate Initiative. Policy Integrity submitted comments that support the exploration of implementing a multisectoral carbon price and recommend that the state study a scenario that uses the federal Interagency Working Group’s Social Cost of Carbon.
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Policy Integrity Comments to the Colorado Public Utilities Commission on Electricity Rule Changes
The Colorado Public Utilities Commission is amending its rules relating to utilities, electric resource planning, and renewable energy standards. Policy Integrity submitted comments explaining why the Commission should use Social Cost of Greenhouse Gases estimates to monetize the externalities of carbon pollution. Our recommendations include rule revisions and new language that will help include monetized estimates of climate impacts in all relevant decisionmaking. Policy Integrity also submitted comments and reply comments on additional rule revisions, building on our original comments to further describe how the Commission can best express and apply the Social Cost of Greenhouse Gases.
