Description: Request for withdrawal of technical support documents that provided estimates of social cost of carbon.
Petition for Correction of Social Cost of Carbon for Regulatory Impact Analysis
Filing Date Type File Action Taken Summary 02/24/2014 Not Available Download Request for reconsideration submitted. On February 24, 2014, a coalition of organizations representing various industry and business sectors submitted a Request for Reconsideration (RFR) to OMB regarding OMB’s January 2014 response to the September 2013 Petition for Correction (PFC) of the TSDs prepared as the basis for SCC estimates used by federal agencies in their decision making. The RFR called OMB’s January 2014 response “unsatisfactory,” contending that OMB “supported its terse conclusion with little more than a ‘cut-and- paste’ reiteration of the precise TSD language that concerned the [organizations].” The RFR catalogs the January 2014 response’s alleged shortcomings, including that it had not remedied the “opacity” that characterized the development of the SCC estimates. The organizations also contend that OMB did not comply with its own Information Quality Act guidelines in the development of either the TSDs or the 2014 response. 01/24/2014 Response Download In a response to the September 2013 petition for correction (PFC), OMB addressed the five concerns enumerated in the PFC but concluded that the SCC estimates “provide valuable and critical insight” for regulatory decision making. The response also referred the organizations to the ongoing public comment process on the SCC TSDs, which sought comments “on topics that are consistent with those raised” in the PFC. 11/26/2013 Federal Register Notice Download Notice published of updated Technical Support Document for social cost of carbon. OMB announced the availability of, and requested public comments on, an updated Technical Support Document (TSD) for agencies to use to estimate SCC in their rulemakings. OMB indicated that it was particularly interested in comments on the selection of the models used and the synthesis of the resulting SCC estimates; how the distribution of SCC estimates should be represented in regulatory impact analyses; and the strengths and limitations of the overall approach. The deadline for comments was originally January 27, 2014, but was extended to February 26, 2014. 09/03/2013 Petition Download Petition for correction of social cost of carbon for regulatory impact analysis submitted. Seven organizations—America’s Natural Gas Alliance, the American Chemistry Council, the American Petroleum Institute, the National Association of Home Builders, the National Association of Manufacturers, the Portland Cement Association, and the U.S. Chamber of Commerce—submitted a “Petition for Correction” to the Office of Management and Budget (OMB) seeking withdrawal of two Technical Support Documents issued in 2010 and 2013 that provide estimates of the social cost of carbon (SCC). Federal agencies, including EPA and the Department of Energy, use SCC estimates in their development of regulations. The petitioners contend that the SCC estimates “fail in terms of process and transparency” because, among other reasons, the development of the estimates did not comply with OMB guidance under the Information Quality Act. The petition also asserts that the modeling for the estimates did not provide “a reasonably acceptable range of accuracy for use in policy-making” and that the estimates will skew agency decision-making by focusing on the global, rather than domestic, benefits of reducing carbon emissions. The petitioners also argued that using the estimates would cause agencies to violate the Administrative Procedure Act (APA) and that the estimates themselves violated the APA.