On February 26th, 2021, the Biden Administration published “interim” social cost of greenhouse gas (SC-GHG) estimates for carbon dioxide, methane, and nitrous oxide (link). In early May, the Administration requested public comment on the “interim” estimates and technical document, with comments due June 21st, 2021 (link). This publication represents the public comments EPRI submitted.
EPRI’s public comments are technical in nature and based on extensive EPRI SC-GHG related research and expertise covering SC-GHG estimation as well as application (i.e., use). The SC-GHGs are important metrics that are used in regulations and other federal decisions to assess policy proposals, justify actions, and set standards with significant financial and social implications. The U.S. Government SC-GHG estimates are also being considered by U.S. states and other countries. However, SC-GHG estimates are complex to calculate and use, requiring multi-century modeling of potential future global societies, climate change, sea level rise, and economic damages from climate change. EPRI’s public comments identify critical technical issues that need to be addressed for reliable, robust, and stable estimates and use in the near-term with the interim estimation methodology and policy applications, as well as in the longer-run in terms of scientific challenges that need to be overcome and the type of scientific review of future methodologies needed for public confidence in the estimates and the use of those estimates.
The Biden Administration has also requested “final” SC-GHG estimates by January 2022. EPRI’s comments identifying scientific challenges, and the opportunities for addressing them, inform that process as well. In general, EPRI’s comments stress the importance of putting science first and developing SC-GHG estimates as robust scientific metrics that can meaningfully inform decisions and instill public confidence in the insights generated.
Authors Steven Rose et al