Comments on the U.S. Social Cost of Carbon

Abstract

Our organizations respectfully submit these comments regarding EPA’s use of the Interagency Working Group’s valuation of the Social Cost of Carbon to assess the costs and benefits of its greenhouse gas emissions guidelines for existing fossil fuel-fired power plants (the Clean Power Plan). Our organizations have separately and independently submitted other comments regarding the proposed emissions guidelines themselves. We strongly affirm that the current Social Cost of Carbon (SCC) values are sufficiently robust and accurate to continue to be the basis for regulatory analysis going forward. As demonstrated below, if anything, current values are significant underestimates of the SCC. As economic and scientific research continues to develop in the future, the value should be revised, and we also offer recommendations for that future revision