by Marlo Lewis, Jr.
As appearing on the Competitive Enterprise Institute’s Blog
CEI submitted comments yesterday on the Environmental Protection Agency’s (EPA) proposed greenhouse gas (GHG) emission standards for motor vehicles during model years 2023 through 2026. The EPA claims that the proposed standards will deliver $91 billion in cumulative climate change mitigation benefits by 2050. Our comments show those benefits are illusory.
The EPA bases its climate benefit calculation on the Biden administration Interagency Working Group’s (IWG) social cost of carbon (SCC) estimates. For those unfamiliar with the concept, the SCC is an estimate in dollars of the cumulative long-term damage caused by an incremental ton of carbon dioxide (CO2) emitted in a specific year. That number also represents an estimate of the benefit of avoiding or reducing one ton of CO2 emissions in that year. In the IWG’s central estimate, the SCC rises from $51 per ton in 2020 to $85 per ton in 2050.
Our comments chiefly do two things:
- Explain why SCC estimation is too speculative, assumption-driven, and vulnerable to political manipulation to inform public policy decisions; and
- Document the IWG’s many dubious methodological decisions that bias SCC analysis in favor of climate alarm and regulatory activism.