Interesting… Greenwire says
GREENWIRE | The Trump administration said Wednesday it will further truncate environmental reviews by eliminating Biden-era guidance to consider greenhouse gas emissions and climate change when weighing new energy projects.
“when weighing new energy projects”
But the way I read the federal register notice, it’s for all projects.
Here’s the link to the Federal Register notice.
Here’s the link to the CEQ interim guidance from 2023.
It involves using what is surely one of the most bogus numbers ever calculated– the Social Cost of Carbon. To be fair, I don’t think the people at CEQ understood how it was calculated.
This is in the footnote to the 2023 guidance:
This guidance is not a rule or regulation, and the recommendations it contains may not apply to a particular situation based upon the individual facts and circumstances. This guidance does not change or substitute for any law, regulation, or other legally binding requirement, and is not legally enforceable. The use of non-mandatory language such as “guidance,” “recommend,” “may,” “should,” and “can,” describes CEQ policies and recommendations. The use of mandatory terminology such as “must” and “required” describes controlling requirements under the terms of NEPA and the CEQ regulations, but this document does not affect legally binding requirements.
I was exhausted from just reading the guidance (and didn’t make it all the way through), let alone figuring out how to incorporate it in a NEPA doc. I wonder whether NEPA folks at any agencies took it seriously?
There would have been a way for CEQ to work with agencies to figure out a relatively simple way to consider GHGs. Needless to say, the 2023 guidance is not that. Maybe if they’d done that the agencies would have found it useful, and it wouldn’t have been tossed by the next Admin. I think that that is also good advice for this Admin.
Trump’s decision is based on Trump’s Executive Order 14154, Unleashing American Energy which says “[t]he calculation of the ‘social cost of carbon’ is marked by logical deficiencies, a poor basis in empirical science, politicization, and the absence of a foundation in legislation …” However, this does not do away with executive agencies’ duty to follow laws duly enacted by Congress, including NEPA, which requires accurate scientific analysis of proposed actions, and the Trump administration assertions about the social cost of carbon dioxide emissions are not well founded, so agencies would be wise to follow the best available science on this instead of following the baseless assertions of the Trump administration.
Second, in my view, the Trump Admin’s criticism of SCC is anything but baseless. Check out my answer to Anonymous. https://forestpolicypub.com/2025/05/29/federal-register-notice-rescinds-2023-ceq-interim-guidance-on-greenhouse-gas-emissions-and-climate-change/comment-page-1/#comment-535087
You don’t have to believe me.. you can just look at the inputs to the calculations for yourself.
Or you can read this.. by people who work on this and apparently assume it’s helpful. I don’t think they ask themselves the question very deeply.. “does anyone use this?” “does it provide useful information.” In my mind, bogus numbers tend to distract, rather than clarify, I also think we have to be honest in that people who develop numbers are probably not the most objective in weighing in on how useful they are.
If each interdisciplinary team had a climate scientist on board it may have been feasible to meet the requirements. Would the results make a difference in which alternative got selected? No. Land and Resource Management Plans I have seen don’t contain goals or objectives related to GHG emissions.
That probably would have been in the next series of plan revisions, DCs for GHG emissions..
I kind of understand calculating emissions but think of only one kind of project, fuels treatment trade-offs assumptions about potential wildfires how intensely they would burn in different areas..there are so many assumptions the actual numbers (in terms of trade-offs) are such that anyone can assume anything and probably get any answer.
But to me SCC is in a different category of bogusness.. because they have to project the future, the value of future impacts (including ag, assuming no adaptation, very bogus!!!)
Here’s what Wikipedia says..
SCC calculations typically involve (from Wikipedia, with my comments in italics):
Projecting Future Emissions: Based on economic growth, technological change, and demographics. (and we’re so good at that.. the shale revolution, the birth dearth…)
Modeling Climate Responses: Simulating atmospheric CO2 levels, temperature increases, sea level rise and other changes.(but of course creatures like plants live on a microsite which no models predict)
Assessing Impacts: Evaluating effects on agriculture,[26] health,[27] energy use, infrastructure, and ecosystems.[28] (yup, they can assess impacts on ag and ecosystems- without involving the adaptation folks like us)
Monetizing Damages: Converting impacts into monetary terms.[1][29] (sure. why not?)
Discounting Future Damages: Applying a discount rate to reflect time preferences.[30][31]
What occurs to me about this is how the natural humility of economists, whose predictions are tested regularly, becomes invisible and is both an input and an output of this effort.
Key Factors that Influence Social Cost of Carbon[32][33]
Climate sensitivity (how much warming one ton of carbon causes, estimated via IAMs)[34]
Economic assumptions/growth projections[35]
Discount Rate Choice[36]
Global vs. domestic damage scope[37][38]
Inclusion of non-market damages (i.e. ecosystem services)[39][40]
I hope economic historians will examine exactly how economists were bamboozled into going along with this. Myself, I found it demoralizing as a federal employee to calculate numbers that were obviously bogus, But there was no one to complain to..