Comments on the U.S. Social Cost of Carbon

Ceronsky, Megan; Revesz, Richard L.; Keohane, Nathaniel O.; Cleetus, Rachel; Convery, Frank J.; Schwartz, Jason A.; Howard, Peter H.; Sterner, Thomas; Johnson, Laurie T.; Wagner, Gernot

Our organizations respectfully submit these comments regarding EPA’s use of the Interagency
Working Group’s valuation of the Social Cost of Carbon to assess the costs and benefits of its
greenhouse gas emissions guidelines for existing fossil fuel-fired power plants (the Clean Power
Plan). Our organizations have separately and independently submitted other comments regarding
the proposed emissions guidelines themselves.
We strongly affirm that the current Social Cost of Carbon (SCC) values are sufficiently robust and
accurate to continue to be the basis for regulatory analysis going forward. As demonstrated below,
if anything, current values are significant underestimates of the SCC. As economic and scientific
research continues to develop in the future, the value should be revised, and we also offer
recommendations for that future revision.


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Academic Units
International and Public Affairs
Published Here
February 9, 2015