Dear Deputy Administrator Mancini, We, the undersigned Associations, submit the following comments in response to the Office of Management and Budget (“OMB”), May 7, 2021, Notice of Availability and Request for Comment on the “Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990” (“Notice”).
At the outset, the Associations reassert their commitment to addressing climate change and extend their continued support for sound, transparent regulatory policy reducing greenhouse gas (“GHG”) emissions. The Social Cost of Carbon, Methane, and Nitrous Oxide (collectively, “the Social Cost of GHG” or “SC-GHG”) estimates have a far reaching impact on regulatory policy affecting nearly every sector of the economy, including members of the Associations. They have also increasingly been used by states and other entities to justify policies that similarly affect members. For these reasons, a subset of the Associations have long sought to engage in the policy of using such estimates as well as the Interagency Working Group on the SC-GHG (“IWG”) process for developing the estimates. Most recently, several Associations wrote the Administration requesting to engage with the IWG as it works to revise the SC-GHG estimates.2