I was testifying before the Senate Environmental Public Works Committee on the social cost of carbon last month, Howard Shelanski was testifying to the House Committee on Oversight and Government Reform on the exact same topic. As Shelanski was serving in his new role as Administrator of the Office of Information and Regulatory Affairs (part of the Office of Management on Budget), his perspective naturally differed greatly from mine. In this post, I’ll walk through some of Shelanski’s key points, and explain how they unwittingly reveal just how dubious the “social cost of carbon” is as a guide to federal rulemaking.