Today, the Texas Public Policy Foundation formally opposed the Biden Administration’s destructive and scientifically flawed proposal to include the so-called “social cost of carbon” (SCC) in analyzing the effect of certain rules and regulations. This approach relies on embarrassingly absurd emissions forecasts, generates vastly uncertain cost estimates, and ignores observable facts and the history of human behavior.  

“Quantifying the social cost of carbon is just a back-door way of making reliable energy, like oil and gas, more expensive,” said Jason Isaac, the Director of TPPF’s Life:Powered initiative. “It does not ‘follow the science’ but rather misuses science to justify regulations that won’t make our air cleaner or safer and will have little, if any, effect on reducing global temperatures. What the SCC will do is dramatically increase Americans’ cost of living, drive up the price of just about everything we produce, kill jobs, and make us less competitive in the world. The SCC is virtue signaling at its worst.”

The official comment submitted by Isaac and TPPF details how SCC is based on laughable predictions about emissions levels that go far beyond even the International Energy Agency and United Nation’s suspect data.  

[O]ne model described by [Bjorn] Lomborg predicts that, under the Intergovernmental Panel on Climate Change’s (IPPC’s) highest emissions scenario (SSP 5/RCP 8.5) with no adaptation, 187 million people will experience catastrophic flooding events annually by 2100, with damages totaling $55 trillion, or 5.3% of global GDP,” Isaac wrote. “However, even in this impossibly high emissions scenario, improving dikes reduces flood costs by more than 99.9%, down to $38 billion per year. Even when the additional $24 billion in annual dike costs are considered, the total cost in the adaptation scenario is still 99.8% less than with no adaptation.” 

“The three economic forecasting models used to derive the SCC—which go by the acronyms DICE, FUND, and PAGE—assume far less adaptation than what is accomplished in the model above. For example, the PAGE model does not allow for adaptation to sea level rise that might occur if the global average temperature rises more than 2 degrees Celsius. There is no empirical evidence to say that the assumptions in the three models used by the interagency working group are superior to those in other models, yet these three models will be used to justify policies that will have vast impacts on the U.S. economy. This type of problem is endemic in the entire SCC exercise.” 

Isaac concludes, “The social cost of GHG emissions can in no way outweigh the social benefits of the energy production that creates those emissions. Attempting to socially engineer a transition away from fossil fuels, working against market forces, will result in less wealth and less ability to adapt. The United States should instead allow the production of inexpensive and efficient energy from fossil fuels to facilitate wealth and climate adaptation that make the SCC so small that it will be difficult to measure.”