WASHINGTON, D.C. – U.S. Senator Shelley Moore Capito (R-W.Va.), Ranking Member of the Senate Environment and Public Works (EPW) Committee, today requested that the “Interagency Working Group on the Social Cost of Greenhouse Gases” (Working Group) extend the current public comment period by 45 days, as well as basic information regarding the Working Group’s transparency and plans for public engagement. The Working Group is currently accepting public comments on where to apply the Social Cost of Greenhouse Gases in areas of federal government decision-making. The public comment period is currently scheduled to conclude on June 21. This letter follows a previous letter Ranking Member Capito sent in February to President Biden asking the administration to postpone any current efforts to set interim cost values on the social cost of greenhouse gases. The cost assumptions set by this working group process will have significant implications for regulatory policies and the national economy. 

The full letter can be found here and below:

Dear Chair Rouse, Acting Director Young, and Director Lander,

I write to request that the “Interagency Working Group on the Social Cost of Greenhouse Gases” (Working Group) Co-Chairs provide additional information and a 45-day extension for the public comment period on the document titled “Notice of Availability and Request for Comment on ‘Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive Order 13990.’” Extending the comment period will allow the public a greater opportunity to provide detailed input on the wide-ranging issues contained in the public comment notice.

As I wrote President Biden in February, it is critically important for the Working Group to establish and follow an accountable and transparent process in their current consideration of how and where to use the “Social Cost of Greenhouse Gases” (SC-GHG) in the federal government’s “decision-making, budgeting, and procurement” process. Under the president’s order, the SC-GHG are used to “determine the social benefits of reducing greenhouse gas emissions when conducting cost-benefit analyses of regulatory and other actions.” A hurried, opaque process, without sufficient public input, is likely to lead the EPA and other agencies to base broad, costly climate policies on flawed calculations. The potentially wide-reaching applications of the SC-GHG makes it imperative that the Working Group use a credible and transparent process to develop the costs, including undergoing a full regulatory review of the underlying scientific information, technical information, and models.

In addition to a necessary 45-day extension for the public comment period, I ask that you, as the Senate-confirmed leadership of the Working Group, respond to the following questions and requests no later than July 6, 2021 to ensure the transparency of the Working Group’s actions and decisions. 

  • Will you consider the comments received in this public comment period in a manner consistent with and prescribed by the Administrative Procedure Act (APA)?
  • Will you make all submitted comments publicly available?
  • Please provide a list of the participants of the Working Group from the White House and each agency, including title and office.
  • Is the Working Group planning to hold any public meetings? If so, please provide a list and details of any planned or anticipated public meetings, including date and location.
  • Please provide details on any additional opportunities for public comment and stakeholder feedback that will be available prior to any Working Group consideration and action on the following:
  • recommendations on the application of the SC-GHG in areas of decision-making, budgeting, and procurement by the federal government;
  • publication of the final SC-GHG cost calculations;
  • recommendations on the process to review and update the SC-GHG to ensure the costs are based on the best available economics and science; and
  • recommendations to revise the methodologies associated with calculating the SC-GHG.
  • Will the Working Group follow the APA process when updating the SC-GHG cost estimates?

It is vital that the American public have confidence in the Working Group’s activities, particularly in its establishment and use of the SC-GHG. This confidence can only be achieved through a transparent process, with sufficient public input. Thank you for your consideration and I look forward to your reply.

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