I'll admit, I'm naive about what really goes on in DC. I read the papers and think that things are really changing. This article by Arden Rowell in the Illinois Law Review makes the claim that President Trump's deregulatory push doesn't really change anything. I've excerpted everything that addresses the social cost of carbon:
No one should be happy with how Trump has led the administrative state in his first 100 days. Trump’s aggressively deregulatory rhetoric has been combined with widespread ineffectiveness when it comes to actually directing agencies. ...
While it remains unclear whether Trump will withdraw from the Paris Accords—the historic climate-change agreements struck last year—he did issue an order on Promoting Energy Independence and Economic Growth, rescinding almost all of President Obama’s executive climate actions and ordering the Environmental Protection Agency (“EPA”) to begin reconsidering the massive Clean Power Plan. Importantly, that order withdrew President Obama’s directions to agencies to use a centralized estimate of the “social cost of carbon” to estimate the likely impact of government action on climate change. On its face, this action alone may look revolutionary, as the social cost of carbon (sometimes called “the most important number you’ve never heard of”) had formed the centerpiece of modern U.S. climate-change policy. ...
Finally, consider the likely impact of Trump’s rescission of Obama’s guidance on the social cost of carbon. Agencies were told that the guidance requiring them to use the centralized estimate of the social cost of carbon was rescinded, but this is very unlikely to lead agencies to actually stop using an economic estimate of the likely impact of climate change. Many agencies know themselves to be statutorily required to use some estimate, and the estimate from President Obama’s International Working Group is likely to prove a powerful and easy focus. Not to mention that switching course on the science they rely upon is likely to smack courts as arbitrary and capricious. Furthermore, because reviewing and keeping up with climate science is so incredibly burdensome, agencies are likely to continue to stick with the IWG estimates for some time, rather than having to invest on their own in additional research. As a result, though agencies may begin explicitly noting the domestic vs. international impacts, as Circular A-4 requires (and, in my view, as they should have been doing already), they are otherwise likely to continue cost-benefit as usual—or face judicial reversal. This means that, when carbon emissions would cause too much harm to be cost-justified, regulations will not be promulgated, even when they offer other significant benefits. Or, in other words, though the order seems to be deregulatory on its face, in fact agencies are likely to continue doing largely what they were doing before the order—just with some additional fragmentation across agencies and, admittedly, with a lesser ability to update given new science. ...
Finally, fake deregulation forces companies to deal with costly regulatory fragmentation in two ways. First, as with Trump’s newly decentralized approach to the social cost of carbon, businesses must deal with the potential of differing, and even competing, standards for carbon emissions across agencies. At the same time, companies must prepare for the possibility that consistent federal standards may be rescinded or delayed, plunging them into a twilight of state-specific regulations, as may happen with proposed weakening of federal fuel-efficiency requirements in cars. ...
In sum, the first 100 days of Trump’s administration have been marked by significant sound and fury, with bombastically deregulatory rhetoric combined with high-profile actions. Yet, these actions, while appearing deregulatory on their face, actually largely entrench the status quo. ...
I like the term "fake deregulation" and the circa January 19 status quo (i.e., so I hope this article is correct although there is still a long way to go).
