Summary
The Institute for Policy Integrity criticizes a May 5 OIRA memorandum that instructs federal agencies to stop monetizing climate impacts, arguing that the social cost of greenhouse gases (SC-GHG) remains a valid tool despite uncertainties.
Key insights
- On May 5, the Office of Information and Regulatory Affairs (OIRA) issued a memorandum that directs federal agencies to minimize the consideration of climate impacts in permitting and regulatory decisions, specifically instructing them to "not monetize" these impacts because the uncertainties of the social cost of greenhouse gases (SC-GHG) are deemed too great for reliable decisionmaking.
- The author contends that OIRA's rationale is flawed because the SC-GHG is rigorously developed and accounts for uncertainty; furthermore, the primary uncertainty stems from high-end risk—the possibility that damages are significantly higher than current estimates—which does not justify assigning a zero value to climate damages.
- The document notes that in 2008, a federal appeals court previously rejected similar government claims that the SC-GHG was too uncertain to use, determining that while a range of estimates exists, the value is "certainly not zero."
Cite the original document
- APA
- Schwartz, P. H. M. S. J. A. (2025). Zero Rationality. Institute for Policy Integrity. https://policyintegrity.org/publications/detail/zero-rationality
- Chicago
- Schwartz, Peter Howard, Max Sarinsky, Jason A. Zero Rationality. Institute for Policy Integrity, 2025. https://policyintegrity.org/publications/detail/zero-rationality.
- Wikipedia
- {{cite report |last1=Schwartz |first1=Peter Howard, Max Sarinsky, Jason A. |title=Zero Rationality |publisher=Institute for Policy Integrity |date=13 May 2025 |url=https://policyintegrity.org/publications/detail/zero-rationality |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{schwartz2025zero, author = {Schwartz, Peter Howard, Max Sarinsky, Jason A.}, title = {{Zero Rationality}}, institution = {Institute for Policy Integrity}, year = {2025}, month = may, url = {https://policyintegrity.org/publications/detail/zero-rationality}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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