By Nick Goldstein, vice president of regulatory affairs & assistant general counsel, ARTBA

ARTBA is urging Congress to carefully reconsider using “social cost of carbon” (SCC) estimates in federal regulations.

SCC was developed in 2010 by 13 federal agencies, including the U.S. Department of Transportation, as “an estimate of the monetized damages associated with an incremental increase in carbon in any given year.”

“The vagueness of the SCC presents a variety of dangers to the regulated community,” ARTBA warned in a Feb. 28 statement to the House Committee on Science, Space and Technology Subcommittee on Environment and Subcommittee on Oversight. “The proposal’s lack of specifics as to what types of ‘costs’ are to be measured could enable project opponents to suggest an endless array of considerations which would essentially preclude new transportation improvements from being built.”

Specifically, the association said, “the open-ended nature of the SCC could attempt to hold transportation projects responsible for emissions associated with development occurring after the project is completed. Put another way, a new road could be held accountable for emissions coming from houses and/or businesses built along the road after it is complete.”

ARTBA urged the committee to require further discussion with the regulated community before the SCC is used in future regulations.