Whitehouse, Merkley, Cardin, Van Hollen, Markey & Schatz: FERC is ‘effectively taking the position that carbon pollution has no cost to society.  That is clearly wrong.’



Washington, DC – Six senators have lodged a formal argument with the Federal Energy Regulatory Commission (FERC) calling for it to incorporate the social cost of carbon – the measure of carbon pollution’s long-term harm – in its evaluation of energy projects around the country.  Senators Sheldon Whitehouse (D-RI), Jeff Merkley (D-OR), Ben Cardin (D-MD), Chris Van Hollen (D-MD), Edward J. Markey (D-MA), and Brian Schatz (D-HI) filed the official comment letter with FERC pointing to the mountain of evidence of the need to address carbon pollution built in the years since FERC last reviewed its pipeline guidance in 1999.  FERC has the authority and means to incorporate the social cost of carbon into its environmental review, the senators argue, and with harm from climate change escalating it is more important than ever that it does.

We are seeing changes all across the planet from sea-level rise, to increased frequency of extreme weather events, to glacier loss, to poleward migration of diseases and species,” the senators write.  “These changes, driven by increased carbon dioxide emissions, have significant economic costs.  We will be judged by future generations on our ability to mitigate and adapt to these damages.”


The federal government developed the social cost of carbon as a comprehensive metric for climate change’s harms, including drops in agricultural productivity, public health effects, property damage, and changes in energy costs.  A range of authorities have adopted the social cost of carbon, including courts, corporations, federal agencies, utilities, and international governing bodies.


Nonetheless, the Trump administration and FERC, driven by Trump-appointed commissioners, have weakened or outright refused to acknowledge the social cost of carbon in their decision-making.  In March 2017, President Donald Trump issued an executive order disbanding an important interagency working group charged with formulating the social cost of carbon and withdrew the guidance it had issued.  The Trump administration also directed agencies to use an outdated Office of Management and Budget policy to monetize the value of greenhouse gas emissions from changes in federal regulation.  And FERC will not use the social cost of carbon at all in its cost-benefit analysis.


That is wrongheaded, the senators write.  “As FERC evaluates projects that contribute to greenhouse gas pollution, it must have a comprehensive and defensible estimate of the total costs of greenhouse gas pollution.  The [social cost of carbon] is commonly used to evaluate the economic costs of greenhouse gas pollution, but FERC continues to reject it, effectively taking the position that carbon pollution has no cost on society.  That is clearly wrong,” the senators continue.  “It is also inconsistent with other states, businesses, federal agencies, and countries that now regularly use the social cost of carbon in their project analyses.


The senators’ comment letter is available here.