Comment on the Energy Conservation Program

The social cost of carbon as determined by the Interagency Working Group in their May 2013 Technical Support Document and used by the Department of Energy in its proposed Energy Conservation Standards for Small, Large, and Very Large Air-Cooled Commercial Package Air Conditioning and Heating Equipment is unsupported by the scientific literature, not in accordance with Office of Management and Budget guidelines, fraught with uncertainty, illogical, and thus completely unsuitable and inappropriate for federal rulemaking. As such, use of the social cost of carbon (SCC) in cost/benefit analyses in this proposed rulemaking should be suspended and not revisited until to above-mentioned weaknesses are fully rectified. Given the uncertainties that are involved, the DOE should cease the use of the SCC in this and all regulatory analyses.

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