CHAPTER 1 0. MONETIZATION OF EMISSION REDUCTIONS BENEFITS

TABLE OF CONTENTS

10.1 INTRODUCTION ......................................................................................................... 10-1

10.2 MONETIZING CARBON DIOXIDE EMISSIONS ..................................................... 10-1

10.2.1 Social Cost of Carbon ........................................................................................ 10-1

10.2.2 Monetizing Carbon Dioxide Emissions ............................................................. 10-2

10.3 DEVELOPMENT OF SOCIAL COST OF CARBON VALUES ................................. 10-2

10.3.1 Current Approach and Key Assumptions .......................................................... 10-2

10.3.2 Limitations of Current Estimates ....................................................................... 10-4

10.4 VALUATION OF OTHER EMISSIONS REDUCTIONS ........................................... 10-5

10.5 RESULTS ...................................................................................................................... 10-5

LIST OF TABLES

Table 10.3.1 Annual SCC Values for 2010-2050 from 2010 Interagency Report (in 2007$ per Metric Ton) ....................................................................................... 10-3

Table 10.3.2 Annual SCC Values for 2010–2050 from 2013 Interagency Update (in 2007$ per Metric Ton of CO 2 ) ........................................................................... 10-4

Table 10.5.1 Estimates of Global Present Value of CO 2 Emissions Reduction under

TSLs for Small Three

- Phase Air -Cooled Air Conditioners and Heat
Pumps <65,000 Btu/h ........................................................................................ 10-6

Table 10.5.2 Estimates of Global Present Value of CO 2 Emissions Reduction under

TSLs for Water -Source Heat Pumps.................................................................. 10-7

Table 10.5.3 Estimates o f Domestic Present Value of CO 2 Emissions Reduction under

TSLs for Small Three

- Phase Air -Cooled Air Conditioners and Heat
Pumps <65,000 Btu/h ........................................................................................ 10-8

Table 10.5.4 Estimates of Domestic Present Value of CO 2 Emissions Reduction under

TSLs for Water -Source Heat Pumps.................................................................. 10-9

Table 10.5.5 Estimates of Present Value of NO X Emissions Reduction under TSLs for

Small Three

- Phase Air -Cooled Air Conditioners and Heat Pumps <65,000

Btu/h ................................................................................................................. 10-10

Table 10.5.6 Estimates of Present Value of NO X Emissions Reduction under TSLs for

Water

- Source Heat Pumps ............................................................................... 10-11

10 -iCHAPTER 10. MONETIZATION OF EMISSION REDUCTIONS BENEFITS

10.1 INTRODUCTION

As part of its assessment of the effects of potential energy conservation standards for

small commercial air

- cooled air -conditioning and heating equipment less than 65,000 Btu/h and

water

- source heat pumps , the U.S. Department of Energy ( DOE ) estimated the monetary benefits

of the reduced emissions of carbon dioxide (CO 2 ) and nitrogen oxides (NO X ) that would be
expected to result from each trial standard level ( TSL ) considered for this rulemaking . This
chapter summarizes the basis for the monetary values assigned to emissions and presents the

modeled benefits of e stimated reductions.

10.2 MONETIZING CARBON DIOXIDE EMISSIONS

One challenge for anyone attempting to calculate the monetary benefits of reduced

emissions of CO 2 is what value to assign to each unit eliminated. The value must encompass a
broad range of physical, economic, social, and political effects. Analysts developed the concept
of the social cost of carbon (SCC) to represent the broad cost or value associated with
producing— or reducing —a quantifiable amount of CO 2 emissions

.

10.2.1 Social Cost of Carbon

The SCC is an estimate of the monetized damages associated with an incremental
increase in carbon emissions in a given year. The SCC is intended to include (but is not limited
to) changes in net agricultural productivity, human health, property damages fro m increased
flood risk, and the value of ecosystem services. SCC estimates are provided in dollars per metric

ton of carbon dioxide. A value for the domestic SCC is meant to re present the damages in the
United States resulting from a unit change in carbon dioxide emissions, whereas a global SCC is
meant to reflect the value of damages worldwide.

Under section 1(b) (6) of Executive Order 12866, 1 agencies must, to the extent permitted
by la w, “assess both the costs and the benefits of the intended regulation and, recognizing that
some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a
reasoned determination that the benefits of the intended regulation justify its costs.” The purpose

of the SCC estimates required by the Executive Order is to enable agencies to incorporate the
monetized social benefits of reducing CO 2 emissions into cost- benefit analyses of regulatory
actions. The estimates are presented wit h an acknowledgement of the many uncertainties
involved and with a clear understanding that they will need updating in response to increasing
knowledge of the science and economics of climate impacts.

As part of the interagency process that developed the SCC estimates, technical experts
from numerous agencies met regular ly to explore the technical literature in relevant fields,
discuss key model inputs and assumptions, and consider public comments. The primary objective

10 -1of the process was to develop a ran ge of SCC values using a defensible set of assumptions
regarding model inputs that was grounded in the scientific and economic literature. In this way,
key uncertainties and model differences transparently and consistently inform the range of SCC

estimates developed for use in the rulemaking process.

10.2.2 Monetizing Carbon Dioxide Emissions

When attempting to assess the incremental economic impacts of carbon dioxide
emissions, the analyst faces several serious challenges. A report from the National Research

Cou ncil 2 points out that any assessment will suffer from uncertainty, speculation, and lack of
information about (1) future emissions of greenhouse ga ses, (2) the effects of past and future
emissions on the climate system, (3) the effects of changes in climate on the physical and
biological environment, and (4) the translation of those environmental impacts into economic
damages. As a result, any effort to quantify and monetize the harms associated with climate
change raise s serious questions of science, economics, and ethics and should be viewed as
provisional.

Despite the limits of both quantification and monetization, SCC estimates can be useful

in estimating the social benefits of reducing CO 2 emissions. An agency can estimate the benefits
from reduced (or costs from increased) emissions in any future year by multiplying the change in
emissions in that year by the SCC values appropriate for that ye ar. The n the net present value of
the benefits can be calculated by multiplying each of the future benefits by an appropriate
discount factor and summing across all affected years. This approach assumes that the marginal
damages from increased emissions are constant for small departures from the baseline emissions
path, an approximation that is reasonable for policies that have effects on emissions that are
small relative to cumulative global carbon dioxide emissions.

10.3 DEVELOPMENT OF SOCIAL COST OF CARBON VALUES

In 2009, an interagency process was initiated to develop a preliminary assessment of how
best to quantify the benefits from reducing carbon dioxide emissions. To provide consistency in

how benefits are evaluated across Federal agencies, the Administration sought to develop a
transparent and defensible method, specifically designed for the rulemaking process, to quantify
avoided climate change damages from reduced CO 2 emissions. The interagency group did not
undertake any original analysis. Instead, it combined SCC estimates from the literature to use as
interim values until a more comprehensive analysis could be conducted. The outcome of the
preliminary assessment was a set of five interim values: global SCC estimates for 2007 (in
2006$) of $55, $33, $19, $10, and $5 per ton of CO 2

. 3 Those interim values represented the first
sustained interagency effort within the U.S. government to develop an SCC for use in regulatory
analysis. The results of that preliminary effort were presented in several proposed and final rules.

10.3.1 Current Approach and Key Assumptions

After the release of the interim values, the interagency group reconvened regular ly to improve the SCC estimates. Speci fic ally, the group considered public comments and further

10 -2explored the technical literature in relevant fields. The interagency group relied on three
integrated assessment models commonly used to estimate the SCC . The models are known b y their acronyms of FUND, DICE, and PAGE. Those three models frequently are cited in the peer

reviewed literature and were used in the most recent assessment of the Intergovernmental Panel
on Climate Change. Each model was given equal weight in developing SCC values.

Each model takes a slightly different approach to calculating how increases in emissions
produce economic damages. A key objective of the interagency process was to enable a
consistent exploration of the three models while respecting the diff erent approaches taken by the
key modelers in the field. An extensive review of the literature identified three sets of input
parameters for the models: climate sensitivity; socioeconomic and emissions trajectories; and

d iscount rates . A probability distribution for climate sensitivity was specified as an input to all
three models. In addition, the interagency group used a range of scenarios for the socioeconomic
parameters and a range of values for the discount rate. All other model features were lef t unchanged, relying on the model developers’ best estimates and judgments.

The interagency group selected four SCC values for use in regulatory analyses. Three
values are based on the average SCC from the three integrated assessment models, at discount
rates of 2.5 percent, 3 percent , and 5 percent. The fourth value, which represents the 95 th

percentile of the SCC estimate across all three models at a 3-percent discount rate, is included to

represent larger

- than

- expected effects from temperature change s fa rther out in the tails of the

SCC distribution. The values increase in real terms over time . Additionally, the interagency
group determined that a range of values from 7 percent to 23 percent should be used to adjust the
global SCC to calculate domestic effects, although preference is given to consideration of the
global benefits of reducing CO 2 emissions

. Table 10.3.1 presents the values in the 2010

interagency g roup report. 4

Table 10.3.1 Annual SCC Values for 2010-2050 from 2010 Interagency Report (in

2007$ per Metric Ton )

Year Discount Rate ( % )

5 3 2.5 3

Average Average Average 95 th Percentile

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

The SCC values used for the analysis of the effects of potential standards for hearth
product s were generated using the most recent versions of the three integrated assessment

10 -3models that have been published in the peer-reviewed literature, as described in the 2013 update
from the interagency working group (revised November 2013). Table 10.3.2 shows the updated

sets of SCC estimates in 5 -year increments from 2010 to 2050. The full set of annual SCC
estimates for 2010–2050 is presented in appendix 10B of this TSD. The central value that
emerges is the average SCC across models at a 3-percent discount rate. To capture the
uncertainties involved in regulatory impact analysis, however, the interagency group emphasizes
the importance of including all four sets of SCC values.

Table 10.3.2 Annual SCC Values for 2010–2050 from 2013 Interagency Update (in

2007$ per Metric Ton of CO 2 )

Year Discount Rate (%)

5 3 2.5 3

Average Average Average 95 th Percentile

2010 11 32 51 89

2015 11 37 57 109

2020 12 43 64 128

2025 14 47 69 143

2030 16 52 75 159

2035 19 56 80 175

2040 21 61 86 191

2045 24 66 92 206

2050 26 71 97 220

10.3.2 Limitations of Current Estimates

The interagency group recognizes that current models are imperfect and incomplete.

Because k e y uncertainties remain , current SCC estimates should be treated as provisional and

revisable . Estimates doubtless will evolve in response to improved scientific and economic
understanding. The 2009 National Research Council report points out the tension between
producing quantified estimates of the economic damages from an incremental ton of carbon and

the limits of current modeling efforts. Several analytic challenges are being addressed by the
research community, some by research programs housed in many of the Federal agencies
participating in the interagency process. The interagency group intends to review and reconsider

SCC estimates periodically to incorporate expanding knowledge of the science and economics of
climate impacts, as well as improvements in modeling.

In summary, in considering the potential global benefits resulting from reduced CO 2 emissions, DOE used the values from the 2013 interagency report, applying the GDP price

deflator to adjust the values to 2013$. For the four SCC values, the values of emission s in 2015

were $1 2.0, $40.5, $62.4, and $119 per metric ton avoided (values expressed in 2013 $). DOE
derived values after 2050 using the relevant growth rates for 2040–2050 in the interagency
update.

10 -4DOE multiplied the CO 2 emissions reduction estimated for each year by the SCC value
for that year under each discount rate . To calculate a present value of the stream of monetary
values, DOE discounted the values in each of the four cases using the same discount rate that had

b een used to obtain the SCC values in each case.

10.4 VALUATION OF OTHER EMISSIONS REDUCTIONS

DOE considered the potential monetary benefits of reduced NO X emissions attributable to

the TSLs considered for hearth product ignition device s. As noted in chapter 9, new or amended
energy conservation standards would reduce NO X emissions in those States that are not affected
by emissions caps. DOE estimated the monetized value of NO X emissions reductions resulting

from each TSL based on estimates of environmental damag e found in the scientific literature.

E stimates suggest a wide range of monetary values, from $4 76 to $4,893 per ton (in 2013 $). 5

DOE calculated monetary benefits using a median value for NO X emissions of $2,684 per short ton (in 2013$), at real discount rates of 3 percent and 7 percent.

DOE continues to evaluate appropriate values for monetizing avoided SO 2 and Hg

emissions. DOE did not monetize those emissions for this analysis

.

10.5 RESULTS

Table 10.5.1 and Table 10.5.2 p resent the global values of CO 2 emissions reductions from

standards for small commercial air -cooled air conditioners and heat pumps and water

- source heat

pumps for each efficiency level

.

10 -5Table 10.5.1 Estimates of Global Present Value of CO 2 Emissions Reduction under

TSLs for Small Three

- Phase Air -Cooled Air Conditioners and Heat
Pumps <65,000 Btu/h

Efficiency

Level SCC Case*

5% discount
rate, average* 3% discount
rate, average* 2.5% discount

rate, average* 3% discount rate,

95 th percentile*

Million 201 3$

Primary Energy Emissions

ASHRAE/0 23 110 177 340

1 53 261 420 808

2 103 498 799 1541

3 127 617 990 1910

4 149 721 1156 2231

5 159 768 1232 2378

Upstream Emissions

ASHRAE/0 1.3 6.5 10 20

1 3.1 15 25 48

2 6.0 29 47 91

3 7.4 36 59 113

4 8.7 43 68 132

5 9.3 45 73 140

Full

- Fuel

- Cycle Emissions

ASHRAE/0 24 116 187 360

1 56 277 445 856

2 109 527 846 1632

3 135 654 1049 2023

4 157 763 1224 2362

5 168 814 1305 2518

Note: The potential emissions reduction for efficiency levels more stringent than those specified
by ASHRAE Standard 90.1

- 201 3 were calculated relative to the efficiency levels that would

result if ASHRAE Standard 90.1

- 201 3 standards were adopted.

* For each of the four cases , the corresponding global SCC value for emissions in 2015 is $ 12.0

,

$ 40.5 , $ 62.4 , and $ 119 per metric ton ( 2013 $).

10 -6Table 10.5.2 Estimates of Global Present Value of CO 2 Emissions Reduction under

TSLs for Water- Source Heat Pumps

Efficiency

Level SCC Case*

5% discount
rate, average* 3% discount
rate, average* 2.5% discount
rate, average* 3% discount rate,

95 th percentile*

Million 2013$

Primary Energy Emissions

ASHRAE/0 **

- - - -

1 8.7 42 68 131

2 99 482 773 1491

3 186 902 1448 2794

4 253 1228 1972 3804

5 347 1681 2698 5206

Upstream Emissions

ASHRAE/0 **

- - - -

1 0.5 2.5 4.0 7.7

2 5.8 28 45 88

3 11 53 85 164

4 15 72 116 224

5 20 99 159 306

Full

- Fuel

- Cycle Emissions

ASHRAE/0 **

- - - -

1 9.2 45 72 138

2 105 510 818 1579

3 196 955 1533 2958

4 267 1300 2088 4028

5 367 1780 2856 5512

Note: The potential emissions reduction for efficiency levels more stringent than those specified
by ASHRAE Standard 90.1

- 201 3 were calculated relative to the efficiency levels that would

result if ASHRAE Standard 90.1

- 201 3 standards were adopted.
* For each of the four cases, the corresponding global SCC value for emissions in 2015 is $12.0,

$40.5, $62.4, and $119 per metric ton (2013$).

** There are no reductions for the ASHRAE level because there is no market share projected at

the federal baseline in the base case.

After calculating global values of CO 2 emissions reductions for each efficiency level

, DOE calculated domestic values as a range of from 7 percent to 23 percent of the global values.

Results for domestic values are presented in Table 10.5.3 and Table 10.5.4

.

10 -7Table 10.5.3 Estimates of Domestic Present Value of CO 2 Emissions Reduction under

TSLs for Small Three

- Phase Air -Cooled Air Conditioners and Heat
Pumps <65,000 Btu /h

Efficiency

Level SCC Case*

5% discount
rate, average* 3% discount
rate, average* 2.5% discount
rate, average* 3% discount rate,

95 th percentile*

Million 2013$

Primary Energy Emissions

ASHRAE/0 1.6 to 5.2 7.7 to 25.3 12.4 to 40.6 23.8 to 78.3

1 3.7 to 12.3 18.3 to 60.0 29.4 to 96.5 56.6 to 185.9

2 7.2 to 23.7 34.9 to 114.5 55.9 to 183.7 107.9 to 354.5

3 8.9 to 29.3 43.2 to 141.9 69.3 to 227.7 133.7 to 439.3

4 10.4 to 34.2 50.4 to 165.8 80.9 to 265.9 156.1 to 513.0

5 11.1 to 36.5 53.8 to 176.7 86.3 to 283.5 166.5 to 547.0

Upstream Emissions

ASHRAE/0 0.1 to 0.3 0.5 to 1.5 0.7 to 2.4 1.4 to 4.6

1 0.2 to 0.7 1.1 to 3.6 1.7 to 5.7 3.4 to 11.0

2 0.4 to 1.4 2.1 to 6.7 3.3 to 10.8 6.4 to 20.9

3 0.5 to 1.7 2.5 to 8.4 4.1 to 13.5 7.9 to 25.9

4 0.6 to 2.0 3.0 to 9.8 4.8 to 15.7 9.2 to 30.3

5 0.6 to 2.1 3.2 to 10.4 5.1 to 16.7 9.8 to 32.2

Full

- Fuel

- Cycle Emissions

ASHRAE/0 1.7 to 5.5 8.2 to 26.8 13.1 to 43.0 25.2 to 82.9

1 4.0 to 13.0 19.4 to 63.6 31.1 to 102.2 59.9 to 196.9

2 7.6 to 25.1 36.9 to 121.3 59.2 to 194.6 114.3 to 375.4

3 9.4 to 31.0 45.7 to 150.3 73.4 to 241.2 141.6 to 465.3

4 11.0 to 36.2 53.4 to 175.5 85.7 to 281.6 165.4 to 543.3

5 11.8 to 38.7 57.0 to 187.2 91.4 to 300.2 176.3 to 579.3

Note: The potential emissions reduction for efficiency levels more stringent than those specified
by ASHRAE Standard 90.1

- 201 3 were calculated relative to the efficiency levels that would

result if ASHRAE Standard 90.1

- 201 3 standards were adopted.

* For each of the four cases , the corresponding SCC value for emissions in 2015 is $ 12.0 , $ 40.5

,

$ 62.4 , and $ 119 per metric ton ( 2013 $).

10 -8Table 10.5.4 Estimates of Domestic Present Value of CO 2 Emissions Reduction under

TSLs for Water- Source Heat Pumps

Efficiency

Level SCC Case*

5% discount
rate, average* 3% discount
rate, average* 2.5% discount
rate, average* 3% discount rate,

95 th percentile*

Million 2013$

Primary Energy Emissions

ASHRAE/0 **

- - - -

1 0.6 to 2.0 3.0 to 9.7 4.7 to 15.6 9.2 to 30.1

2 6.9 to 22.8 33.7 to 110.8 54.1 to 177.8 104.4 to 343.0

3 13.0 to 42.7 63.1 to 207.5 101.4 to 333.1 195.6 to 642.5

4 17.7 to 58.1 86.0 to 282.5 138.0 to 453.5 266.3 to 874.9

5 24.3 to 79.7 117.7 to 386.7 188.8 to 620.5 364.5 to 1197.5

Upstream Emissions

ASHRAE/0 **

- - - -

1 0.0 to 0.1 0.2 to 0.6 0.3 to 0.9 0.5 to 1.8

2 0.4 to 1.3 2.0 to 6.5 3.2 to 10.5 6.1 to 20.2

3 0.8 to 2.5 3.7 to 12.2 6.0 to 19.6 11.5 to 37.8

4 1.0 to 3.4 5.1 to 16.6 8.1 to 26.7 15.7 to 51.4

5 1.4 to 4.6 6.9 to 22.7 11.1 to 36.5 21.4 to 70.3

Full

- Fuel

- Cycle Emissions

ASHRAE/0 **

- - - -

1 0.6 to 2.1 3.1 to 10.3 5.0 to 16.5 9.7 to 31.9

2 7.3 to 24.1 35.7 to 117.3 57.3 to 188.3 110.5 to 363.2

3 13.7 to 45.2 66.9 to 219.7 107.3 to 352.7 207.1 to 680.3

4 18.7 to 61.5 91.0 to 299.1 146.1 to 480.2 281.9 to 926.3

5 25.7 to 84.3 124.6 to 409.3 199.9 to 656.9 385.8 to 1267.8

Note: The potential emissions reduction for efficiency levels more stringent than those specified
by ASHRAE Standard 90.1

- 201 3 were calculated relative to the efficiency levels that would

result if ASHRAE Standard 90.1

- 201 3 standards were adopted.
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.0, $40.5,

$62.4, and $119 per metric ton (2013$).

** There are no reductions for the ASHRAE level because there is no market share projected at

the federal baseline in the base case.

Table 10.5.5 and Table 10.5.6 present the present -values of the cumulative NO X emissions reductions from standards for small commercial air -cooled air conditioners and heat
pumps and water-source heat pumps for each efficiency level. Monetary v alues are calculated
using the average dollar- per -ton values assigned to NO X emissions at 7- percent a nd 3- percent

discount rates.

10 -9Table 10.5.5 Estimates of Present Value of NO X Emissions Reduction under TSLs for

Small Three

- Phase Air

- Cooled Air Conditioners and Heat Pumps

<65,000 Btu/h

Efficiency

Level 3% Discount Rate 7% Discount Rate

million 2013$

Primary Energy Emissions

ASHRAE/0 3.3 1.4

1 7.8 3.2

2 15 6.4

3 19 7.9

4 22 9.2

5 23 9.9

Upstream Emissions

ASHRAE/0 3.6 1.4

1 8.6 3.3

2 17 6.6

3 21 8.2

4 24 9.5

5 26 10

Full

- Fuel

- Cycle Emissions

ASHRAE/0 7.0 2.8

1 16 6.5

2 32 13

3 39 16

4 46 19

5 49 20

Note: The potential emissions reduction for efficiency levels more
stringent than those specified by ASHRAE Standard 90.1

- 201 3 were calculated relative to the efficiency levels that would result if ASHRAE

Standard 90.1

- 201 3 standards were adopted.

10

- 10Table 10.5.6 Estimates of Present Value of NO X Emissions Reduction under TSLs for

Water- Source Heat Pumps

Efficiency

Level 3% Discount Rate 7% Discount Rate

million 2013$

Primary Energy Emissions

ASHRAE/0 *

- - 1 1.3 0.5

2 15 6.0

3 27 11

4 37 15

5 51 21

Upstream Emissions

ASHRAE/0 *

- - 1 1.4 0.5

2 16 6.2

3 30 12

4 41 16

5 56 22

Full

- Fuel

- Cycle Emissions

ASHRAE/0 *

- - 1 2.7 1.1

2 31 12

3 57 23

4 78 31

5 107 43

Note: The potential emissions reduction for efficiency levels more
stringent than those specified by ASHRAE Standard 90.1

- 201 3 were calculated relative to the efficiency levels that would result if ASHRAE

Standard 90.1

- 201 3 standards were adopted.

* There are no reductions for the ASHRAE level because there is no
market share projected at the federal baseline in the base case.

10

- 11REFERENCES

1. Presidential Documents

-- Executive Order 12866

-- Regulatory Planning and Review

, October 4, 1993. < http://www.archives.gov/federal- register/executive

orders/pdf/12866.pdf >

2. National Research Council, Hidden Costs of Energy: Unpriced Consequences of Energy

Production and Use , 2010. National Academies Press. Washington, DC.

< http://www.nap.edu/catalog.php?record_id=12794 >

3. Interagency Working Group on Social Cost of Carbon, Social Cost of Carbon for

Regu latory Impact Analysis under Executive Order 12866, February, February 2010.
United States Government. Washington, D.C.

< http://www.whitehouse.gov/sites/default/files/omb/inforeg/for

- agencies/Social -Cost-ofCarbon- for -RIA.pdf >

4. Interagency Working Group on Social Cost of Carbon, Technical Update of the Social
Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866 , Ma y 2013; revised November 2013. United States Government. Washington, D.C.

< http://www.whitehouse.gov/s ites/default/files/omb/assets/inforeg/technical -updatesocial

- cost -of-carbon- for -regulator- impact -analysis.pdf >

5. U.S. Office of Management and Budget (OMB), 2006 Report to Congress on the Costs
and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tribal

Entities , 2006. Washington, DC.

< http://www.whitehouse.gov/sites/default/files/omb/assets/omb/inforeg/2006_cb/2 006_c b_final_report.pdf >

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