Thank you for the opportunity to comment on the Technical Support Document, entitled, “Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis under Executive Order 12866.”
I respectfully submit that the interagency working group's estimate of the social cost of carbon (SCC) is flawed in at least one important respect. The working group's estimate is based on the global SCC, which includes the costs that carbon dioxide emissions impose on the entire world population, although most of the costs are borne by people outside the United States. For the reasons set forth below, policies unilaterally adopted by the United States in the absence of an international agreement to combat climate change should instead be guided by the domestic SCC, which includes only the costs that carbon dioxide emissions impose on residents of the United States. Moreover, even if the use of the global SCC might be viewed as appropriate, only Congress and the president, not the interagency working group, have the democratic legitimacy to adopt such a measure.