Joint Comments Regarding NYSDEC Social Cost of Carbon Guidance
A broad coalition of environmental, public interest, and clean energy groups urges NYSDEC to make two changes to the proposed Social Cost of Carbon (SCC) guidelines. First, DEC should establish a single, uniform SCC for use in regulatory processes. Second, given the ample evidence that the impacts of climate change are likely to get significantly worse over time, DEC should apply a low discount rate of 2% and a high, 95th percentile damages estimate to reflect this reality. In addition, we recommend that DEC assist agencies by providing guidance on appropriate SCC values for less common GHG emissions, including black carbon.