On November 8, as world leaders and environmental ministers gathered in Bonn, Germany to hash out the gritty details for implementing the Paris climate agreement, the U.S. Environmental Protection Agency published a little-noticed document on its website. It argued that a proposed two-year delay of the Obama administration’s rule limiting methane emissions from the oil and gas industry would save money, despite years of scientific and economic evidence to the contrary.

To back up its claim, the EPA made what might seem like a few small changes to a metric known as the social cost of carbon, which agencies use to figure out the climate benefits of a particular regulation. Most notably, in the case of the methane rules, the EPA argued that it should only have to calculate how emissions reductions benefit the U.S. and the U.S. alone — a complete reversal from how costs of climate regulations were calculated previously.

And while that might seem like merely an extension of the administration’s America First agenda into the realm of climate policy, legal and environmental experts warn that the Trump administration’s willingness to eschew scientific consensus for political advantage also typifies a worrying trend of manufacturing facts and reality to match their policy goals.

“The administration is definitely trying to mess with the numbers to make it look like they’re saving money on these repeals,” Denise Grab, western regional director for the Institute for Policy Integrity, told ThinkProgress. “But they aren’t considering the massive benefits to the public, and the economic and scientific consensus on the substantial benefits that could be achieved by reducing this greenhouse gas pollution.”


During the 2016 presidential campaign, Donald Trump often railed against perceived government overreach by federal agencies, which he blamed for job losses and industry declines. But repealing regulations, in practice, requires more than rhetoric — it requires evidence to back up the claim. The Obama administration spent years compiling scientific and economic analyses to justify its proposed regulations, and while the Trump administration can’t ignore those analyses, it can manipulate them to support its own agenda.

For a slew of recently proposed repeals or delays, the Trump administration’s primary strategy for justifying its actions has been manipulating the social cost of carbon to minimize the climate benefits of a regulation while magnifying the potential costs.

The social cost of carbon — or, in the case of the methane rule, the social cost of methane — is a figure that accounts for the economic and social benefits associated with preventing an additional ton of carbon (or methane) from entering into the atmosphere. Greenhouse gases like carbon dioxide and methane trap heat, which in turn drives climate change — and climate change has a slew of economic and public health consequences, from lost economic activity associated with dangerously hot days to economic damages from increasingly severe natural disasters like hurricanes and wildfires.

In March, when Trump signed a broad executive order on energy, he — among other things — disbanded the inter-agency working group that dealt with the social cost of carbon, and officially withdrew all of the group’s technical documents. Instead of using the figure agreed upon during the Obama administration — which was about $41 per ton of carbon dioxide — Trump directed agencies to calculate their own social cost of carbon using procedures issued by the Office of Management and Budget in 2003.

As a result, agencies are now left largely to their own devices when it comes to calculating the costs and benefits of a particular regulation — or, as is mostly the case these days, eliminating a particular regulation.

Calculating the exact amount of money saved from preventing a ton of carbon dioxide from entering the atmosphere is seriously wonky business. It requires using numerous economic and scientific models to identify the anticipated impacts of climate change, and how that is in turn made worse by each additional ton of greenhouse gas in the atmosphere.


For the EPA and the Department of the Interior’s Bureau of Land Management, one common thread with calculating the social cost of carbon under the Trump administration has been focusing only on the domestic costs and benefits of a particular regulation, not global costs and benefits. But environmental and legal experts warn that relying only on a domestic social cost of carbon not only seriously skews the real-world benefits of climate action, but lacks any kind of scientific or economic consensus.

The models used to calculate the social cost of carbon were all global, and thus examined the economic consequences of climate change on a global scale because climate change is by definition a global problem. Emissions released in the United States or in China won’t just raise sea levels along the United States or Chinese coastlines — sea levels will rise throughout the entire world.

In a similar vein, because climate change is a global problem, it’s an interconnected problem — one country taking action on climate will likely spur other countries to do the same, while one country turning its back on climate action might have a similar affect around the globe. Thus, for economists looking at the impact of climate change, the actions of a single country can’t be separated from the global community. According to Science Magazine, more than $30 of the Obama administration’s social cost of carbon figure came from projected climate impacts outside of the United States.

“You can’t look at climate change and put a fence around the impacts of one country,” Andres Restrepo, a staff attorney for the Sierra Club, told ThinkProgress. “That’s not scientifically, or socially, how it works.”

For the methane rule delay and repealing the Clean Power Plan, the EPA is also using a discount rate that places a lot more emphasis on saving money today rather than saving money in the long term. According to Restrepo, using a discount rate in this way represents an extreme departure from conventional economic wisdom.

“There is just no basis for it, especially when you’re dealing with something like climate change,” he said. “What it essentially does is make it sound like the impacts of carbon emissions are very small.”


Federal agencies’ use of the social cost of carbon has been challenged in court before, though only by industry representatives who felt that the Obama administration had overstepped its authority in calculating and using the metric. In 2016, in response to challenges from the refrigeration industry, a federal court ruled that the Obama administration’s use of the social cost of carbon — specifically, the fact that it took global benefits into account — was neither arbitrary nor capricious. Now that the tables have turned, it’s possible environmental groups could challenge the Trump administration’s interpretation of the metric.

“Statutorily, courts have said that agencies cannot assume that the cost of carbon is zero. How they score it is more open to interpretation, but they have to have a rational way of scoring it,” Restrepo said. “If they’ve basically done something that dramatically understates what the benefit of the rule they are proposing to repeal or delay is, then that is arbitrary and capricious.”

The way federal agencies under Trump — led largely by the EPA — treat the social cost of carbon is deeply illustrative of the administration’s relationship with both climate change specifically and fact-based evidence in general.

Considering a domestic-only social cost of carbon — or a social cost of carbon with a high discount rate — might reflect the administration’s political priorities, which include undermining climate action and fostering growth for fossil fuel extraction. Choosing to limit the impacts of a particular policy to the boundaries of the United States also mirrors the administration’s self-proclaimed interest in an America First stance, wherein the concerns of the U.S. are held above any kind of interest in global well-being. It’s the same attitude on full display at this year’s U.N. Conference on Climate Change, where the United States has retreated from ringleader to silent observer, hosting just one official event that was aimed at promoting fossil fuels.

Downplaying the benefits of climate regulation certainly helps bolster the administration’s claim that these limits on pollution are job-killing constraints on the American economy — but like Trump’s famous “Chinese hoax” assessment of climate change, such claims also play fast and loose with the facts at hand.

Generally speaking, environmental regulations poll favorably with the majority of Americans, meaning the Trump administration’s de-regulatory approach to environmental stewardship faces serious challenges not just in courts, but in public opinion. One way to make policies more palatable is by showing possible economic benefits — and one way to show possible economic benefits is to manipulate science and data.

It’s what EPA Administrator Scott Pruitt is trying to do by expelling EPA-funded scientists from EPA science advisory boards, making room for more industry representation. It’s what Secretary of Energy Rick Perry reportedly wanted to do with the department’s report on coal plant closures, pushing back when the report found that natural gas, not environmental regulations, were causing the declines in coal-fired power plants. And it’s what the administration is doing by considering only benefits to the United States when looking at climate-related regulations, despite volumes of scientific evidence showing that climate change is a very real, very global problem.

“I can’t understate how important this issue is,” Restrepo said. “Is global climate change, is it a global phenomenon or a domestic phenomenon? The answer to that question has the potential to affect every single thing that the government does that bears on greenhouse gas in some way or another.”