SB1584 (Transparency and Honesty in Energy Regulations Act of 2025) prohibits heads of federal agencies from considering the social cost of carbon, methane, nitrous oxide, or any social‑cost estimate for greenhouse gases in cost‑benefit analyses, rulemakings, guidance, or any other agency action. The bill defines those social‑cost measures by reference to specific Interagency Working Group and EPA technical documents and by a catch‑all definition covering any monetized estimate of incremental greenhouse‑gas damages.
Beyond the ban, the bill requires agencies to report to four congressional committees within 120 days on agency uses of these estimates since January 2009, and it directs agencies to limit environmental considerations in permitting and regulation to those explicitly required by statute and to make greenhouse‑gas valuation consistent with OMB Circular A‑4. For compliance officers and regulated industries, the bill would change how agencies quantify benefits from emissions reductions, narrow the universe of admissible environmental factors in adjudications, and trigger retrospective housekeeping of prior analyses.
At a Glance
What It Does
The bill bars federal agencies from considering any monetized social‑cost estimate for greenhouse gases (including carbon, methane, and nitrous oxide) in cost‑benefit analyses, rulemaking, guidance, or other agency actions and as a justification for those actions. It also requires agencies to report past uses back to 2009 and to align valuation practices with Office of Management and Budget Circular A‑4.
Who It Affects
Directly affected are federal agencies that use greenhouse‑gas valuations (e.g., EPA, DOE, DOI, DOT) and any regulated entities whose compliance costs or obligations rely on those valuations—power generators, oil & gas producers, heavy industry, and utilities. Indirectly affected are lawyers, economists, and consultants who prepare regulatory impact analyses and states or localities that rely on federal valuing methods in permitting and planning.
Why It Matters
Monetized social‑cost estimates have been a central input to justify and calibrate climate‑related regulations; removing them shifts the evidentiary basis for benefits calculations and could weaken justification for stricter standards. The retrospective reporting requirement and the mandate to follow A‑4 tie this change to both oversight and methodology, meaning agencies may need to revisit past rules and alter how future benefits are presented to courts, stakeholders, and Congress.
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What This Bill Actually Does
SB1584 has three operational pillars: a statutory prohibition, a retrospective accounting requirement, and new constraints on how agencies incorporate environmental effects into permitting and regulatory analysis. The definitions section lists the target estimates — naming specific Interagency Working Group technical support documents (2010; technical updates in 2013/2016; the 2021 interim estimates) and several EPA regulatory impact analyses from 2023–2024 — and then extends coverage to “any other” monetized estimate of incremental greenhouse‑gas damages.
That language makes clear the drafters intend to block both the canonical federal social‑cost figures and successor or independent monetizations.
The core prohibition says agency heads may not “consider” the social cost of carbon, methane, nitrous oxide, or any social‑cost estimate in cost‑benefit or cost‑effectiveness analyses mandated by law or Executive Orders 12866 and 13563, in rulemakings, in guidance, in any other agency action, or as a justification for agency action. Practically, agencies that have incorporated monetized climate benefits into regulatory impact analyses must stop using those figures as part of the calculus supporting a rule or guidance document.On the retrospective side, each agency must report to four congressional committees (Senate Environment and Public Works; Senate Energy and Natural Resources; House Energy and Commerce; House Natural Resources) within 120 days of enactment.
The report must enumerate proposed and final rulemakings, guidance documents, and agency actions since January 2009 that used the social cost of carbon or related greenhouse‑gas monetizations, including where such figures were used under Executive Order 12866 or other authority.Finally, the bill tightens what environmental information agencies may weigh in permits and regulations: agencies must use only those environmental considerations explicitly required by statute in adjudications or regulatory processes and must “strictly use the most robust methodology” available, avoiding methods deemed arbitrary or ideologically motivated. It also instructs agencies to make greenhouse‑gas valuation consistent with OMB Circular A‑4—covering issues such as domestic versus international effects and the choice of discount rates—and to initiate changes to existing rules and policies as needed to achieve that consistency.
Together, these provisions would both remove a common quantitative input for climate benefits and redirect agencies toward a narrower, A‑4‑centric approach to valuation and statutory interpretation.
The Five Things You Need to Know
The bill prohibits agencies from considering any monetized estimate of the social cost of carbon, methane, nitrous oxide, or any greenhouse gas in cost‑benefit/cost‑effectiveness analyses, rulemakings, guidance, or any other agency action.
Definitions explicitly target Interagency Working Group and multiple EPA technical/regulatory documents (2010, 2013/2016 updates, 2021 interim estimates, and EPA 2023–2024 RIAs) and also sweep in successors and “any other” monetized estimates.
Within 120 days of enactment each agency must report to specific Senate and House committees the number of proposed and final rulemakings, guidance documents, and agency actions since January 2009 that used those social‑cost estimates.
In permitting adjudications and regulatory processes agencies may only use environmental considerations that are explicitly required by statute; any other environmental consideration is barred and agencies must use what they judge the “most robust methodology” available.
Agencies must align greenhouse‑gas valuation with OMB Circular A‑4 (including treatment of domestic vs. international effects and discount rates) and, where necessary, initiate processes to change rules, regulations, policies, or actions to achieve that alignment.
Section-by-Section Breakdown
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What counts as a 'social cost' and which documents are targeted
The bill defines the social cost terms by reference to a small set of Interagency Working Group and EPA documents (including 2010, 2013/2016 updates, the 2021 interim estimates, and multiple EPA regulatory impact analyses from 2023–2024) and then adds a broad catch‑all — “any other estimate” of monetized incremental damage. For practitioners this matters: naming the canonical IWG and EPA texts prevents agencies from claiming they weren’t covered, while the catch‑all language aims to block independent monetizations or third‑party figures used in analyses.
Broad ban on using social‑cost estimates in agency work
Section 3 makes it unlawful for agency heads to consider social‑cost estimates in statutory cost‑benefit or cost‑effectiveness analyses (explicitly referencing Executive Orders 12866 and 13563), rulemaking, guidance, or “any other agency action,” and forbids using such estimates as justification for actions. The practical effect is to remove monetized climate damages from the evidentiary foundation agencies typically use when weighing benefits against regulatory costs; it reaches both formal and informal actions by using broad phrasing like “any other agency action.”
Mandatory retrospective inventory of past uses since 2009
Agencies must produce a report within 120 days that catalogs the number of proposed and final rulemakings, guidance documents, and agency actions since January 2009 that used social‑cost estimates, and submit it to four named congressional committees. This creates a centralized, time‑bounded record designed for oversight and possible legislative follow‑up; it also imposes a nontrivial compliance task—agencies will need to search archives, RIAs, and guidance libraries to identify covered instances.
Limits on environmental considerations and a requirement to follow OMB A‑4
This two‑part section first restricts permitting and regulatory adjudications to environmental considerations explicitly required by statute and bars other environmental factors in those processes; it further instructs agencies to use the “most robust methodology” and to avoid methods that are arbitrary or ideologically motivated. Second, it requires that greenhouse‑gas valuation be, where permitted by law, consistent with OMB Circular A‑4 (2003), including how agencies treat domestic vs. international effects and discount rates, and directs agencies to initiate processes to revise any rules or policies necessary to achieve that consistency. Together these mechanics steer agencies away from globalized, long‑term social‑cost approaches toward a narrower, A‑4‑based valuation framework.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Fossil fuel producers and energy‑intensive industries (utilities, coal, oil & gas, heavy manufacturing) — by removing monetized climate benefits, the bill reduces a common component used to justify stricter emissions standards and may lower the regulatory burden or compliance costs these sectors face.
- Permitted project proponents (mining, pipeline, power plant developers) — by restricting environmental factors to those explicitly required by statute, the bill narrows the scope of considerations in permitting adjudications that can be used to deny or condition approvals.
- Companies and counsel that prepare regulatory impact analyses — greater methodological certainty if agencies standardize on OMB Circular A‑4 could reduce analytic dispute and litigation over valuation approaches.
- Members of Congress and oversight offices opposed to using social‑cost figures — the retrospective report supplies a political and factual basis for oversight and further legislative action.
Who Bears the Cost
- Federal agencies (EPA, DOE, DOI, DOT and others) — they must stop using established social‑cost metrics, prepare the mandated retrospective reports, and may need to reopen or revise prior RIAs and rules to conform to the new constraints and to OMB A‑4.
- Environmental and public‑health NGOs and affected communities — removing monetized climate benefits will make it harder to demonstrate net benefits of climate‑protective rules, potentially weakening regulatory justification and reducing legally recognized quantifications of benefits.
- Economists, academic researchers, and consultants who develop social‑cost estimates — the bill curtails the use of widely recognized monetized metrics and may reduce demand for that analytical work in the federal regulatory context.
- Courts and litigants — the change may shift litigation strategies and add procedural challenges about whether agencies complied with the prohibition, producing new rounds of administrative‑law disputes and possible record‑keeping disputes over what counts as “consideration.”
Key Issues
The Core Tension
The central dilemma is between methodological rigor and completeness versus the need to account for global, long‑term climate harms: the bill advances a stricter, statute‑bound, A‑4‑centered approach that limits what counts as admissible environmental evidence, which increases predictability for regulated parties but risks undercounting the transboundary and intergenerational benefits of emission reductions and shifting regulatory outcomes away from climate‑protective measures.
The bill raises implementation and interpretive questions that will shape its real‑world effect. First, the statute bars agencies from “considering” social‑cost estimates, but it does not set out an enforcement mechanism or private right of action; enforcement would likely occur through agency managers, OMB oversight, or litigants alleging unlawful consideration in court.
Proving that an agency “considered” a social‑cost figure (versus merely acknowledging external literature) may produce dense fact disputes and filings, and agencies might respond by burying references in supporting materials or qualitative discussion rather than monetized tables.
Second, the command that agencies use only environmental considerations “explicitly required under an Act of Congress” narrows administrators’ discretion but also raises questions where statutes are phrased broadly (for example, obligations to consider “public health” or “environmental impacts” without enumerating specifics). The bill’s instruction to “strictly use the most robust methodology” and to avoid methods that are “arbitrary or ideologically motivated” imports vagueness; those are managerial standards vulnerable to political interpretation, and they could be litigated as arbitrary‑and‑capricious on either side.
Finally, force‑fitting greenhouse‑gas valuation into OMB Circular A‑4 (a 2003 framework not designed around global, long‑lived climate externalities) risks systematically downplaying international and long‑term climate damages through discounting and territorial framing, altering the cost‑benefit balance in ways that the bill’s sponsors likely intend but that may conflict with statutory commands to consider broader impacts.
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