On Monday, the White House announced it will open up a new round of public comments on the social cost of carbon (SCC) — the metric government agencies use to measure the economic damage of carbon dioxide emissions, and thus the benefit of regulations that cut them.
“In response to public and stakeholder interest in SCC values, [Office of Management and Budget’s] Office of Information and Regulatory Affairs (OIRA) will provide a new opportunity for public comment on the estimates in addition to the public comment opportunities already available through particular rulemakings,” Howard Shelanski, OMB’s Administrator for OIRA, wrote in a White House blog post. “Details on this public comment process will be published soon in the Federal Register.”
The occasion for the public comment period is a slight tweak to the SCC’s value, bringing it down roughly $1. The SCC’s estimates actually cover a range of scenarios, and the latest revision brought the four estimates for 2015 to $12, $37, $57 and $109. The last update in May put the equivalent numbers at $12, $38, $58 and $109, respectively, while the initial estimates back in 2010 were $5.7, $23.8, $38.4 and $72.8.
Critics of the Obama Administration characterized the May update of the SCC — which first appeared in an update to microwave regulations — as “improper,” as “dramatically increased,” as evidence of the President’s lack of transparency, as an attempt to enshrine environmental ideology in law, or as an undemocratic power grab. But the fact is every rulemaking that involved the SCC operated as a de facto opportunity for the public to comment on the merits of the SCC itself. Indeed, after the initial 2010 release, it was a slew of public criticism from scientists that the SCC was too low that drove the May 2013 revision. So characterizations that the SCC was “slipped” into regulations — or claims by critics that it was a “secretive swoop” to “make any potential benefits of proposed rules and regulations look a lot more valuable” — are deeply misleading.
“Those estimates have been out for public comment in several proposed rulemakings since May,” Shalenski wrote. “Agencies have already received comments that are under review.”
The three models that generate the SCC are not actually owned by the government. They’re managed by outside scientists, their source code is all publicly available, and their results are constantly peer-reviewed. The government chooses certain parameter inputs for the models, but that’s the extent of its involvement in the guts of the calculations. And it was changes to the underlying structure of the models by those scientists, and not any change in the government’s inputs, that resulted in May’s big increase.
The Union of Concerned Scientists did point out in July that while the opportunities for public comment on the SCC have always been available, they have not been as clear, prominent or well-organized as they could be. So opening up a public comment opportunity on the SCC itself, rather than just its individual uses in rulemakings, seems a positive step toward a more streamlined and user-friendly comment process.