AGA Coalition Comments June 2021 on Social Cost of Greenhouse Gases (GHGs)

On June 21, 2021, AGA joined a multi-association coalition comment letter filed with the White House Office of Management and Budget (OMB) regarding the “Technical Support Document: Social Cost of Carbon, Methane and Nitrous Oxide Interim Estimates under Executive Order 13990.” In the comments, AGA and the other coalition Associations reassert our commitment to addressing climate change, and we express continued support for sound, transparent regulatory policy for reducing GHGs. We support appropriate consideration of GHG emissions as part of the benefit-cost analyses for regulatory actions required under the longstanding E.O. 12866 OMB regulatory review process. However, we emphasize that the divergence among subjective assumptions about societal costs can become compounded with each step of the process for developing social costs of GHGs (SC-GHG), and become increasingly difficult to accurately estimate the farther they are projected into the future. This severely limits the usefulness of SC-GHGs for assessing individual projects.

Our top-level recommendations are as follows (see Coalition Comments, Executive Summary on pp. 5-6).

• The process should be transparent and include full engagement and participation by the public.
• All estimates should undergo proper peer review.
• The IWG should explicitly limit the SC-GHG use outside of regulatory impact analyses.
• The IWG should harmonize its work and clarify its role with related Administrative Initiatives.
• The IWG should improve its major modeling assumptions/inputs and presentation of the estimates.
• The IWG should more fully expand its approach to addressing uncertainty.
• The IWG should conduct a more complete and transparent account of intergenerational issues.
• The IWG should follow the Nation Academies of Science (NAS) directions and Circular A-4 and include an estimate of domestic benefits.

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