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 In October 2020, DEC published draft guidance for New York State agencies on what value of carbon to use, focusing on the IWG’s 2016 Social Cost of Carbon estimates.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.