On June 21, APGA joined a coalition of 23 trade associations—including the U.S. Chamber of Commerce, American Gas Association, American Public Power Association, and National Association of Manufacturers—in responding to the administration’s request for comment on the technical support document (TSD) that underlies the interim values recently set for the social cost of carbon (SCC), methane (SCM), and nitrous oxide (SCN) (collectively, SC-GHGs).
The TSD, developed by an interagency working group (IWG), was released in February in response to Executive Order 13,990 and outlines monetary values for how the administration prices the release of a given greenhouse gas (GHG). The coalition’s comments cover a range of concerns, including pointing out that earlier identified deficiencies in the quality of SC-GHGs have not yet been addressed; major modeling assumptions/inputs need improvement; use of SC-GHGs should be explicitly limited outside of regulatory impact analyses; any additional IWG activity should be transparent with additional public participation; and the IWG and its development of the SC-GHGs should abide by the Administrative Procedures Act.
The SCC has historically been utilized in cost-benefit analyses of certain rulemakings, such as the Department of Energy’s minimum appliance efficiency rules. However, some advocates are pushing for them to be applied more broadly moving forward in all aspects of the federal government’s decision-making, such as permitting, purchasing, and other rulemakings. A
recent article overviews these differing opinions, including citing the coalition’s comments.
A copy of the coalition’s comments is available
here.
For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at
rlani@apga.org.