This publication includes EPRI’s public comments submitted to the New York State Department of Environmental Conservation (DEC) in November 2020 in response to DEC’s request for comment on their proposal Establishing a Value of Carbon: Guidelines for Use by State Agencies. Among other things, DEC proposed specific social cost of carbon (SCC) values, as well as values for other greenhouse gases (GHGs), as estimates that can be used to evaluate the economic climate benefits of reducing a unit of carbon dioxide and other emissions. The Electric Power Research Institute (EPRI) has produced an extensive body of research surrounding SCC estimation and its use, insights from which have directly informed recommendations by the National Academy of Science, Engineering and Medicine SCC Committee, and have contributed to the SCC academic literature base for over a decade. These analyses, including in-depth assessment of the inner workings of the modeling framework developed by the U.S. Government’s Interagency Working Group on Social Cost of Greenhouse Gases for valuing carbon dioxide and other GHGs, serve as the basis for EPRI’s comments on DEC’s proposal. EPRI’s comments outline concerns with the SCC modeling approach used by DEC, and with the discount rates proposed, as well as identifies technical carbon value application issues for DEC to consider. EPRI recommends that DEC reconsider their proposed SCC estimates, and offers DEC improved SCC estimates with greater scientific reliability, or EPRI recommends that DEC use marginal cost estimates as an alternative. EPRI also recommends that DEC provide guidance on carbon value application issues and recognize fundamental technical challenges in considering future updates to SCC estimates. In addition to the recommendations, EPRI’s detailed comments provide technical discussion of research supporting these recommendations.
Authors Chris DeLyser Roney