Executive agencies employ the “social cost of carbon” (SCC), which aims to quantify the economic harm caused by greenhouse gases (GHGs) to argue that the benefits of proposed rules outweigh the costs. But the SCC demonstrates the limitations of economic CBA in climate policymaking. Despite widespread scholarly attention to and excitement about the SCC, researchers have failed to settle upon a consensus figure of dollar cost per ton of carbon dioxide emitted. Rather, as I will discuss, the SCC’s history is one of speculative modeling, back and- forth debates, and obstructive litigation. Further, the SCC undermines environmental justice by perpetuating executive branch CBA, which obstructs regulations, privileges industry perspectives over advocates, and suppresses value-based policy arguments.
Ultimately, the SCC is a bandage on the executive branch’s self-inflicted wound. The executive branch created the mandate that federal agencies’ climate rules be cost-benefit efficient, which is a requirement rooted not in any statute, but in executive orders and internal guidance documents. Moving forward, the federal government should orient its climate regulations not towards economic efficiency and value maximization, but towards aggressively serving the aims of environmental justice.
