Earlier this month, the Institute for Energy Research (IER) submitted a formal comment on proposed federal emission standards for new and modified sources in the oil and gas sector. The novelty of the government’s cost/benefit assessment of the rules was their use of the “social cost of methane,” which is analogous to the more familiar “social cost of carbon” but, of course, applied to a different greenhouse gas. We at IER have tirelessly documented the problems with the “social cost of carbon” as a tool for federal policymakers, and yet the “social cost of methane” is even more dubious.