SENSE? COHERENCE? WHO DOES HE THINK HE'S DISCUSSING?:

Since the Ronald Reagan administration, federal agencies have been required to calculate the costs and benefits of their regulations, and to show that the benefits justify the costs. The analysis of benefits and costs tells agencies how stringent their regulations should be -- and whether to regulate at all.

But what are the benefits of a regulation that cuts greenhouse-gas emissions? The answer comes from the social cost of carbon -- the dollar figure that is designed to monetize the harm from a ton of carbon emissions.

Until 2009, different agencies gave wildly different numbers. To eliminate the inconsistency, the Obama administration created a technical working group, consisting of representatives from numerous offices and departments within the federal government. (Disclosure: As administrator of the Office of Information and Regulatory Affairs, I helped to convene the working group.)

The group's meetings were numerous, lengthy, often boring, painstaking, and dominated by discussions of abstruse issues in science and economics. After many months and extensive public comments, the group produced its technical analysis, which has been periodically updated over the years, ultimately yielding a monetary figure of $36 per ton. [...]

Which brings us to Tuesday's executive order. Disbanding the working group and withdrawing every one of its public documents, Trump offered no number of his own. Instead he said that in monetizing the benefits of greenhouse-gas reductions, individual agencies should follow OMB Circular A-4 (an excellent document issued in 2003, during the George W. Bush administration, that still binds agencies within the executive branch), and especially its guidance on "domestic versus international impacts" and "appropriate discount rates."

That's both technical and vague, but it appears to mean three things. First, individual agencies are now on their own; it's up to them to come up with a social cost of carbon. Second, they should emphasize the domestic rather than global damage (because OMB's 2003 circular favors that approach). Third, they should use discount rates of 7 and 3 percent (as also directed by OMB's circular).

The upshot is that the social cost of carbon could be cut way down, possibly below $5 -- which would mean that on cost-benefit grounds, restrictions on greenhouse-gas emissions would be much harder to justify.

If this reading is correct, then Trump's approach doesn't make a lot of sense. Any administration needs to have coherent policies and hence a uniform number. It would be ridiculous to have disparate ones from the Environmental Protection Agency, the Department of Energy and the Department of Transportation.

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