On November 11th, 2022, U.S. EPA requested public input on its planned peer review of the draft new social cost of greenhouse gases (SC-GHG) estimation methodology that EPA released on the same day.
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, requiring multi-century modeling of potential future global societies, climate change, sea level rise, and economic damages from climate change.
This publication represents the public comments EPRI submitted on December 1st, 2022, on EPA’s planned peer review process and peer review panel candidates. 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), including EPRI’s participation on the National Academies of Sciences, Engineering and Medicine (NASEM) Social Cost of Carbon committee, who’s recommendations EPA’s draft methodology was designed to address.
Overall, EPRI observes that EPA’s proposed peer review and overall scientific process is insufficient to develop scientifically robust and reliable estimates and insufficient for the public to have confidence in the outcome. Based on EPRI’s research and experience in this area, the process needs the following: a revised peer review candidate selection process and list to ensure full and unbiased coverage of the core scientific disciplines underpinning the SC-GHG, a peer review process that is expanded to a scientific review process appropriate for a regulatory methodology with significant implications, a substantial increase in opportunities for public engagement and input, and an improved overall scientific process for developing and using updated SC-GHG estimates. EPRI’s comments discuss each of these recommendations in detail.
Please also see EPRI’s public comments on EPA’s draft new SC-GHG methodology (3002026256), which finds that the methodology and estimates are not yet scientifically reliable and robust for policy use, with the methodology containing multiple significant technical issues and not satisfying the NASEM recommendations. The comments then provide specific recommendations for how to address these issues and move forward.
Authors Steven Rose