In June, we wrote about the Obama Administration increasing the Social Cost of Carbon. Predictably, people were unhappy about being informed of the increase through a regulatory impact analysis that dealt with energy efficiency standards for microwave ovens. The lackluster reveal attracted so much attention that the Obama Administration recently announced that it will provide an opportunity for public comment on the new Social Cost of Carbon. The Social Cost of Carbon helps support the rationale for many of EPA’s rulemakings, including the proposed standards of performance for greenhouse gas emissions from new electric utility generating units. As such, changes to this value should be on the minds of all industries that are tracking greenhouse gas regulation. The Administration will provide details about the comment process in an upcoming Federal Register notice, and Squire Sanders will continue to provide updates about this important issue.
