Subject: Updates to the Social Cost of Carbon, Social Cost of Nitrous Oxide and Social Cost of Methane; Modernizing Regulatory Review Memorandum for Heads of Executive Departments and Agencies.
Dear Acting Director Fairweather, Ms. Leonard, Dr. Fisher and Deputy Administrator Mancini:
On January 20, President Biden signed Executive Order 13990, “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis.”1 A key component of that order focuses on accounting for the benefits and costs of reducing greenhouse gas emissions, including revising guidance regarding the Social Cost of Carbon (SCC), Social Cost of Nitrous Oxide (SCN) and Social Cost of Methane (SCM).
Under the order, the President has directed an interagency working group to update these estimates based in part on recommendations from the National Academies of Sciences (NAS). The group is tasked with publishing interim estimates of these economically significant values within 30 days of the Order and a final set of updated estimates by January 2022.
The undersigned associations support the establishment of an Interagency Working Group on Social Cost of Greenhouse Gases (the “IWG”) with broad interagency representation. We encourage the IWG to adhere objectively and comprehensively to the directed mission and methodology to “consider recommendations of the National Academies of Science, Engineering, and Medicine as reported in Valuing Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxide (2017).”
However, it is not clear what the process is to solicit public and stakeholder input for developing the interim estimates presumably by February 19, 2021 or final estimates by January 2022…
…In summary, we believe that the directives associated with updating these values should adhere to rigorous methodology including ample channels and opportunities for public and stakeholder input.
As members of the regulated community, we look forward to participating in this process.