Transparency and Honesty in Energy Regulations Act of 2025
Transparency and Honesty in Energy Regulations Act of 2025 (S. 1584) would bar federal agencies from considering the social cost of carbon, methane, nitrous oxide, or any greenhouse gas in any action. This includes cost-benefit analyses, rulemakings, guidance, or other agency actions. The bill defines these social costs using a list of specific interagency and EPA documents, and it requires agencies to report to Congress on past uses of such costs since 2009. It also imposes strict limitations on how agencies weigh environmental factors in permitting and regulation, directing agencies to rely only on environmental considerations explicitly required by law and to use robust, non-arbitrary methodologies. Additionally, the bill would push agencies to align economic analyses with the Office of Management and Budget Circular A-4 (discounting and domestic versus international effects) and, if needed, to adjust rules to maintain that alignment. The sponsor is Senator James Lankford, and the bill was introduced in May 2025.
Key Points
- 1Prohibition on considering social costs: Federal agencies may not treat the social cost of carbon, methane, nitrous oxide, or any greenhouse gas as part of cost-benefit analyses, rulemakings, guidance, or other agency actions.
- 2Detailed definitions and sources: The bill defines each social cost (carbon, methane, nitrous oxide, and greenhouse gases) by citing specific interagency and EPA documents (and successors) to determine what counts as the monetized damages from emissions.
- 3Reporting requirement to Congress: Within 120 days of enactment, agency heads must report to certain Congressional committees on how often social cost metrics were used in rulemakings, guidance, and actions since January 2009.
- 4Accuracy and methodology requirements: In permitting adjudications and regulatory processes, agencies must limit environmental considerations to those explicitly required by statute and must use the most robust, non-arbitrary methodologies available.
- 5Alignment with budgeting guidance: Agencies must ensure that estimates of greenhouse gas changes follow the guidance in OMB Circular A-4 (and pursue changes to rules or policies as needed to stay consistent with A-4), addressing domestic vs. international effects and appropriate discount rates.