2. Executive Office of the President · Notable
End the use of social cost of carbon analysis by executive order
Printed page 61 2. Executive Office of the President
“The President should eliminate the Interagency Working Group on the Social Cost of Carbon (SCC), which is cochaired by the OSTP, OMB, and CEA, and by executive order should end the use of SCC analysis.”
What has happened
- Done
The guidance closed the gap. M-25-27, issued by OIRA in consultation with EPA to fulfill section 6, tells agencies to "limit their analysis and consideration of greenhouse gas emissions only to that plainly required in their governing statutes", states that "under this guidance, the circumstances where agencies will need to engage in monetized greenhouse gas emission analysis will be few to none", and instructs that agencies quantifying emissions where case law requires it "should not monetize the impacts from such emissions" because the uncertainties are too great. It also records the consequence of disbanding the working group: "it is no longer Federal government policy to maintain a uniform estimate of the monetized impacts of greenhouse gas emissions." Social cost of carbon analysis is over as a federal practice.
- Partially done
The executive order withdrew the numbers but stopped short of ending the analysis. EO 14154 section 6(b) withdraws every social cost estimate the interagency working group produced; section 6(c) states that the calculation "is marked by logical deficiencies, a poor basis in empirical science, politicization, and the absence of a foundation in legislation" and directs the EPA Administrator, within 60 days, to issue guidance addressing those inadequacies "including consideration of eliminating the 'social cost of carbon' calculation from any Federal permitting or regulatory decision." Consideration, not elimination — and in the meantime section 6(d) tells agencies to value greenhouse-gas changes consistently with the 2003 Circular A-4.
Research log
What was searched, and what didn’t count as evidence
Research notes
Read EO 14154 section 6 in full at govinfo and M-25-27 in full. The Quote joins two acts in one sentence — eliminating the working group and ending the use of the analysis; the first is #92, and both are recorded separately because the executive order delivered the first outright and the second only in stages.
- Action
- eliminate
- Object
- Social cost of carbon analysis in federal decision-making
- ID
- 93