The Department of Energy (“DOE”) is seeking public comment on whether it was appropriate to rely on an estimate of the “social cost of carbon” (“SCC”) in a final rulemaking without undergoing public comment. When DOE published a proposed rule to set energy efficiency standards for microwave ovens in February 2012, it sought public comment on its analysis of the regulation’s contribution toward reducing climate change, using an SCC of $25.6/metric ton. However, in June 2013, DOE defended its final rule with a much higher SCC value of $41.1/metric ton, increasing the anticipated net benefits of the rule by $438 million. An Interagency Working Group on the Social Cost of Carbon had developed this new SCC, and presented it in a “Technical Support Document” (SCC-TSD) as a fait accompli to the public in May.
Our comment to DOE agrees that the SCC is conceptually the right way for agencies to organize their analyses of climate impacts and coordinate across different agencies engaged in climate policy. However, the influential nature of the SCC value for a variety of future policies, as well as the difficulties and uncertainties of calculating the SCC, demand conscientious attention— including public comment and peer review—to the task of getting it right.