In this episode, host Kristin Hayes talks with RFF Fellow and Director of the Social Cost of Carbon Initiative Kevin Rennert about how the Biden administration is approaching new estimates for the social cost of carbon, an assessment of the economic damages of each additional ton of carbon emissions. Rennert provides a brief history of how the federal government has assessed the economic value of carbon pollution, starting with a court mandating in 2008 that the George W. Bush administration consider the benefits of emissions reductions, and up to the Trump administration in recent years opting not to incorporate the international consequences of pollution. Just last week, the Biden administration issued an interim estimate for the social cost of carbon that simply updates the Obama-era estimate by accounting for inflation; here, Rennert elaborates on the complexities that policymakers will have to consider as they develop a more refined and final estimate over the next year.
Listen to the Podcast
- The estimate for the social cost of carbon shrank under the Trump administration: “The Trump administration took a bit of a different approach to the social cost of carbon … It actually kept almost all of the machinery and the approach that the previous interagency working group had put together, but it made two important modifications: one is that it focused only on damages that were being felt within the United States, and the other is that it used a higher rate of economic discount [for valuing future benefits]. These two pieces in tandem actually reduced the number from what was roughly $50 per ton down to as low as about $1 per ton.” (6:27)
- Interim social cost of carbon offers a minor update to Obama-era estimates: “There was a lot of outside commentary on what the federal government should do within this first 30-day period. In the end, I think there was a clear recognition that, with just 30 days, there wasn't sufficient time to really do a robust process to make big changes to the social cost of carbon … In the end, what [the Biden administration] did was actually go back to the Obama-era estimates that were put out in 2013 and 2016, and just update them for inflation.” (8:25)
- Social cost of carbon estimate is contingent on the value placed on future benefits of reduced pollution: “The discount rate is really just a mathematical way of trying to represent that something in the future has a different value to you than it does if you had it today. The discount rate is fundamentally important to the social cost of carbon … If you even just think about these interim estimates that just came out from the federal government, the central discount rate used is 3 percent, which results in a social cost of carbon of $51 per metric ton. But what if you had a 5 percent discount rate, which doesn’t really sound like it’s much higher? That drops the social cost of carbon down from $51 to $14.” (17:26)
Top of the Stack
- “Discounting 101” explainer by Brian Prest
- “Estimating the Value of Carbon: Two Approaches” by Resources for the Future and New York State Energy Research and Development Authority
- “Assessing Approaches to Updating the Social Cost of Carbon” from the National Academies of Sciences, Engineering, and Medicine, by Maureen L. Cropper, Richard G. Newell, Myles R. Allen, Maximilian Auffhammer, Chris E. Forest, Inez Y. Fung, James K. Hammitt, Henry D. Jacoby, Robert E. Kopp, William Pizer, Steven K. Rose, Richard Schmalensee, and John P. Weyant
- “Accelerating Decarbonization of the U.S. Energy System” from the National Academies of Sciences, Engineering, and Medicine, by Stephen W. Pacala, Colin Cunliff, Danielle Deane-Ryan, Kelly Sims Gallagher, Julia Haggerty, Christopher T. Hendrickson, Jesse D. Jenkins, Roxanne Johnson, Timothy C. Lieuwen, Vivian Loftness, Clark A. Miller, William A. Pizer, Varun Rai, Ed Rightor, Esther Takeuchi, Susan F. Tierney, and Jennifer Wilcox
The Full Transcript
Kristin Hayes: Hello, and welcome to Resources Radio, a weekly podcast from Resources for the Future. I'm your host, Kristin Hayes. My guest today is Kevin Rennert, a colleague of mine at RFF, and full disclosure, also a dear friend. Kevin joined RFF as a fellow in 2017, but just before that served as deputy associate administrator for the Office of Policy at the US Environmental Protection Agency. Before that, he worked in various capacities on Capitol Hill, both as a senior adviser on energy for the Senate Finance Committee and as senior professional staff for the Senate Energy Committee.
In addition to being a fellow at RFF, Kevin is also the director of RFF's Social Cost of Carbon Initiative, and his expertise and leadership in this area make him the perfect candidate to join me in discussing the aforementioned social cost of carbon, what it is, why it matters, how it has evolved, and what is happening next with this important number. Stay with us.
Hi Kevin, welcome to Resources Radio. It's really nice to talk with you.
Kevin Rennert: It's so nice to be here. Thanks for having me.
Kristin Hayes: Of course. So I would love to introduce you to our audience, our listening public, and start with a question about you. So what steered your life towards working on energy and environmental issues? Can you tell us a little bit more about your background?
Kevin Rennert: Absolutely. So I, as a kid, was actually always pretty inspired by nature, and I really wanted to understand how it worked, and I really got a lot of my energy from just being outside and enjoying that. So as I got older, I realized that what I wanted most from a scientific standpoint was to understand how nature worked and then to take that understanding and move it to work on problems that were going to help a society. That steered me to actually studying physics and then climate science as a graduate student, and then coming to Washington, DC to try to apply some of that knowledge in ways that would help all the people of the world address climate change.
Kristin Hayes: Okay, well, we're talking about one specific policy determinant today, which is the social cost of carbon. And I guess I really think of the social cost of carbon as lying at the intersection of climate science, which of course is your background, and economics. And I will note to our listeners that Kevin speaks the language of economics quite fluently, even though he is trained as a climate scientist. But Kevin, most of our audience is probably familiar with the concept of the social cost of carbon or what we'll call “SCC” for the next half hour. But can you give us a quick reminder of what it is and how it's used in a US regulatory context?
Kevin Rennert: Sure. The social cost of carbon is an economic tool. It's an estimate of the economic damages that would result from the emission of an additional ton of greenhouse gases. And so, what it does is by looking to the future and saying, “if we emit that additional ton of greenhouse gases and we can figure out over time what the damages are that result from it, we can figure out how to incorporate that into our analysis of actions that we might choose to take in terms of policies or regulations and things of that nature.” And so the way that the federal government incorporates it is in the regulatory analysis it does for big policy actions that it's going to take for a very long time. Since back in the Reagan administration, the federal government has been required to do benefit-cost analysis for these big regulations.
And so as it does that, it's trying to understand both the costs and the benefits of actions that it might be taking. When you do analysis like that, of course you would want it to be as comprehensive as possible. So you'd be trying to take into accounts not just the costs that might be born by, for example, a regulated industry, but also the benefits that might come to society broadly for those costs being undertaken. And the social cost of carbon fits into that by adding the effects of an action on climate change, into that cost-benefit analysis, alongside all those other costs and benefits that you might be thinking about.
Kristin Hayes: So what's the history behind the SCC then? My understanding is that it hasn't always been part of benefit-cost analysis used by the federal government. When did it come into use in federal regulatory decisionmaking?
Kevin Rennert: So the SCC actually started getting used in federal analysis back in 2008 as a result of a court case in which the George W. Bush administration had put forward a regulation that quantified the reductions in greenhouse gas emissions from the regulation, but it didn't actually assign any value to the benefits of those reductions in the economic analysis that accompanied that regulation. The courts agreed with those that filed the suit that by not including the benefits with any dollar value to those reductions, the administration had effectively said that the value of those reductions—the benefits from those reductions—was identically $0. So the judge said “you can actually have a pretty robust debate about what the value of those reductions should be, but identically zero is clearly incorrect.” The court kind of put it back to the George W. Bush administration to start valuing the benefits from reductions in greenhouse gas emissions as a part of all the other things that they incorporate into their benefit-cost analysis.
So that was back in 2008, but the Bush administration as it started doing that, every agency was sort of left to itself to come up with what its value for the social cost of carbon would be to use in its analysis. And as it turned over into the Obama administration, the Obama administration took the approach that a ton of emissions emitted from one place is the same as a ton of emissions emitted from another place. And it really doesn't make sense for the federal government to be using different values for the benefits of those greenhouse gas emissions across the government. So it embarked on this effort to actually come together and bring economists and scientists from across the federal government to think about how the federal government itself should approach this question and actually develop a value for the social cost of carbon.
So over time, what is referred to as the interagency working group on the social cost of greenhouse gases came together and developed an approach based on a lot of academic literature and put forward estimates in 2010, and then updated them periodically throughout the administration in 2013 and 2016 as well. So after the Obama administration, the Trump administration, when it came into the White House, took a bit of a different approach to the social cost of carbon in that it disbanded the interagency working group on the social cost of greenhouse gases, but it actually maintained the approach that that body had put forward for putting for its own social cost of carbon.
So it actually kept almost all of the machinery and the approach that the previous interagency working group had put together, but it made two important modifications. One is that it focused only on damages that were being felt within the United States. And the other was that it has used a higher rate of economic discount for calculating the social cost of carbon. These two pieces in tandem—focusing just on the United States and having a higher rate of discount—actually reduced the number from what was roughly $50 per ton to down as low as about a dollar per ton.
Kristin Hayes: Alright. So then here we are today during the Biden administration. And I would say the SCC is sort of having its moment again, because just a few days before we're recording this episode, the Biden administration is currently working on updating the SCC and just a few days ago, announced an interim update on the road to releasing a more developed update that's due to be finalized in January of 2022. So to help us understand that interim update that was released, can you tell us a little bit more about what goes into the intellectual meat grinder to produce an update like that?
Kevin Rennert: Sure. Well, first, just a few words about the interim updates. I think that there were a lot of things that were under consideration for this interim update, and it actually goes to this executive order that came out on day one of the Biden ministration saying that as an administration, they were going to revisit the social cost of carbon and put out an update that was going to come out within a year, but that there needed to be a step along the way to provide the federal government with an interim estimate to use in its economic analysis, until we got to that fully baked estimate that incorporates all the latest science.
There was a lot of outside commentary on what the federal government should do within this first 30 day period. In the end, I think that there was a clear recognition that, with just 30 days, there wasn't sufficient time to really do a robust process to make big changes to the social cost of carbon that the Biden administration was going to put out. So in the end, what they did was actually go back to the Obama-era estimates that were put out in 2013 and 2016, just updating them for inflation.
So in terms of the meat grinder, I feel like that the meat grinder is really getting started now. And there's a lot, it turns out, that goes into updating the social cost of carbon. It's a very technical exercise, because these estimates do, as you mentioned in the beginning, cut across a lot of different scientific aspects. You think about the four steps of estimating the SCC. You actually need to know something about socioeconomics, where you're headed in terms of emissions, in terms of population, in terms of the economy. You also then need to know something about what the climate system is going to do in response to those emissions.
And of course, then you need, once you have a sense of what the climate system is going to do, you need to know what the result is of what the climate system did on different economic sectors. So you need to translate those changes in the climate into changes in the economy. These are done through things called damage functions. And then finally you need to have a step where you sum up all those damages over time, and then you bring them back into present day dollars, and that's done through economic discounting. So all of those different pieces are actually pretty complicated and some of them actually are slightly a departure from what you see in common practice in terms of how you need projections of emissions that go out pretty far into the future, further than you would normally have.
There's a lot of science to accommodate, and there's a really rich set of academic literature to draw from. It's a big undertaking. Clearly there are a lot of entities that are affected by these estimates. And so it's important that whatever the federal government does, it does so in a really transparent fashion, and it does it in a process that is very inclusive, so that there's a lot of inputs into it, and so that everybody feels like what has happened is the result of a robust process.
Kristin Hayes: Let's pull those pieces apart for just a second then and maybe start with the damage functions. So damage functions implies by its name, the impact that continuing to emit greenhouse gases will have on various parts of the economy also on natural systems, all sorts of things. So obviously the science is also evolving quite quickly, I would guess, on what those damages will look like. So can you say a little bit more about what you expect to see in terms of updating those damage functions and maybe how the science of projecting those has evolved in recent years?
Kevin Rennert: Absolutely. Well, you're exactly right. There has been a huge evolution in terms of both the climate science in our understanding of how the climate system is reacting to increased emissions, as well as in understanding the translation of that change in climate into damages. If you think previously, for example, the models that were used to calculate the social cost of carbon were being run at potentially a global level, meaning that there is just one or two damage functions. That's representing global damages from a global change to regional damage functions, where you might have maybe 14 regions representing all the countries around the world. And so, one of the big advances on the science side has been carried forward by the Climate Impact Lab. They have taken this approach to really look to generate damage functions across multiple economic sectors, where they're working at a very highly resolved level, both spatially and temporally.
They are looking at datasets with county-level data around the world and understanding the effects that they're seeing that is resulting from climate change at that level of spatial resolution. So really, really highly resolved. That's one approach that is really looking to all of the data that's out there to come up with very tailored, small-scale damages. You've also seen other researchers look at similar questions that have been out there before, such as: What is the effect of climate change in terms of damages to crops or to agriculture? And rather than just take a fairly simplified approach, you see in researchers like Fran Moore at UC Davis, who was able to look at the effects on agricultural yield for some of the most important crops around the world and understand what the actual change in the yield was.
But then also incorporates things like the effects on trade to understand what the net economic effects are for a given country, as a result of changing the climate on their agricultural productivity and resulting effects. In addition, you have other people there that are running these integrated assessment models to do things like look at the effects of changes in temperature on what residential and building usage energy looks like, where you have less expenditures on heating in the winter time and greater expenditures on cooling in the summer time, and understanding the net economic effects around the world of things like that using different types of models. There's just been huge advancements across the board. And this is all stuff that the interagency working group is going to have to look to try to incorporate in its updated estimates.
Kristin Hayes: Kevin, you're giving a very good illustration of why this is a complex exercise, because even just hearing the examples you laid out right there, I can think of a thousand more of where you would need to look at this and need to consider this. And I guess I wanted to ask one question: Are there damages where the science really hasn't evolved over the past, let's say 10 years, and where there's still a gap in our knowledge, and we really need to be now turning towards those damage functions with a bit of a blank slate in terms of what we know?
Kevin Rennert: Yeah, you're exactly right. There are most certainly a number of economic sectors for which the literature has not actually delivered quite as robust an update. I would say one of those certainly is the understanding of how to think about ecosystems and the value that ecosystems provide. This is a very challenging question. Actually, that same researcher, Fran Moore, has a paper out that offers one suggestion, and there's a researcher named Steve Newbold who has some thoughts as well, but that's just an area where there is still a lot of work to be done, I would say.
In addition, you hear a lot, and you actually saw this even in some of the pieces that were put up by the federal government in support of the executive order, that things like tipping elements—the idea that you could move, for example, beyond a threshold in the climate system where suddenly you get a big feedback—like a lot of outgassing of methane from the permafrost in the Arctic, or things like that. There's a lot of work to be done to understand those tipping elements from a climate science standpoint. And there's certainly a lot of work to be done to actually incorporate that into the integrated assessment models that you use for calculating the SCC as well.
Kristin Hayes: Well, thanks. Alright. So now let's turn to another crucial component of the SCC, which is the discount rate. You mentioned that a little bit earlier in your comments, and I wanted to circle back with that because I know it's often a controversial part of the calculations of the SCC. As you mentioned, it's one of the factors that the Trump administration really looked to in its changes to the SCC. So occasionally I meet folks who argue that unless the discount rate is zero, you're essentially saying that you don't care about your grandchildren or great-grandchildren. So clearly this was something about looking into the future and impacts in the future, but can you help our listeners understand the concept of discounting and why it can lead to these sort of arguments about the importance of the future?
Kevin Rennert: Absolutely. That's a great question. That's a great way of framing it too, in terms of the same kind of arguments that we get all the time. So economic discounting at its heart is really just about the simple fact that a dollar that you might have today feels different to you than a dollar that you might have in 10 years. And so if I offered you that trade-off, would you like a dollar from me today or a dollar in 10 years or some later period of time, you would think about that and say, “well, if I had a dollar today, I would be able to do something with it. And if I didn't have a dollar until 10 years from now, I would not be able to do something with it until it was 10 years from now.”
And there's a sort of a value in having it now versus having it later. So the discount rate is really just a mathematical way of trying to represent that exact concept: that something in the future has a different value to you than it does if you had it today. And you can turn that on its head a little bit to say, “well, how would you feel about damages that you feel today right now versus damages that you might feel that we're the same magnitude sometime in the future as well?” So the discount rate is really fundamentally important to the social cost of carbon, because first of all, it represents this exact trade-off that you're saying. There's an element of it that says: Well, how much do you value damages that might be felt by someone that isn't you in the future?
The number that you actually put on that is really a very important way of looking at that and evaluating it. It's also fundamentally important just because it actually has a huge sway on the ultimate number. So if you even just think about these interim estimates that just came out from the federal government, the central discount rate that is used is a discount rate of 3 percent. And that results in a social cost of carbon of $51 per metric ton. But what if you had a 5 percent discount rate, which doesn't really sound like it's much higher, right? It turns out that that drops the social cost of carbon down from $51 to $14. On the other hand, if you look just down at two and a half percent, that moves the value from $51 up to $76 per ton.
These relatively small changes in the discount rate actually have a very big change on the resulting social cost of carbon, because what they're effectively saying is the social cost of carbon is summing up damages that happen into the future because a given ton of greenhouse gas emissions that you put out in the atmosphere sticks around in the atmosphere for a very long time. And so damages continue to accrue from it. The discount rate is the way you start to cut off damages in the future and say, “we care about those damages less, and we're not going to add them to our total.”
So this is what's at the heart the comment that people are making to you, that if you don't have an economic discount rate of zero, that means you don't care about a few generations down the line, because effectively you have used a discount rate to discount those damages that would be felt by them away. Everything that I've just said underscores how important the discount rate selected for calculating the social cost of carbon is, but I should be clear that the federal government doesn't just arbitrarily select those discount rates. That 3 percent discount rate that I mentioned was used for the recent intermittent estimate of the SCC, for example, is the discount rate used by the federal government more broadly across its economic analyses to represent what's known as the consumption rate of discount.
That is set out in one of these esoteric yet highly influential government documents known as Circular A-4. Those other values, the two and a half percent and the 5 percent, were carefully selected by the Obama-era interagency working group to represent different kinds of uncertainty with respect to that consumption rate of discount, so that policymakers could assess values for the SCC calculated across each of those discount rates to get a sense of the uncertainty in the SCC that's coming just from that final discounting step. Now, the guidance in Circular A-4 that sets out the consumption rate of discount across the federal government is actually pretty dated and hasn’t been updated in nearly 20 years. So over the time a lot has changed. Even if you apply the same methodology as was used to calculate the 3 percent established in 2003, but updated to include more recent market conditions, you'd end up with a lower consumption rate of discount.
That finding is consistent with the broader economic literature as well with many different lines of evidence, all pointing toward the direction of lowering that discount rate. So in parallel with the process to update the SCC, there's another Biden executive order on modernizing regulatory review, which is widely expected to consider economic discounting issues more broadly, and revisit and modernize the guidance contained in Circular A-4. Now, ideally that update will be done in a way that seamlessly incorporates problems with intergenerational consequences like climate change. So that process could be expected to bear on the discounting approach used for the SCC.
Discounting is clearly a pretty weedy and technical topic. For listeners that want to get a further treatment of this, to get a sense of some of the things to think about when it comes to economic discounting, there are a number of different RFF publications that one can look to. One is actually an explainer that was put out by RFF Fellow Brian Prest. that you can find on the RFF website. Another that actually gets into some of the evolution of the thinking on economic discounting and the current state of the literature was included as a part of a joint technical document that we at the RFF Social Cost of Carbon Initiative authored with the New York State Energy Research and Development Authority, as the state of New York was considering different issues related to coming up with this own valuation for carbon.
Kristin Hayes: That's great. Well, so let me turn to the third major element of the SCC that you referenced at the beginning, which is a number of things under the heading of socioeconomic projections. Can you describe what goes into those projections and why those matter to the calculations of the number?
Kevin Rennert: Absolutely. So the socioeconomic projections encompass a few different things, but at its heart, it's really sort of the state of what's happening in society moving into the future. So it's things like: how many people are there, what is economic growth going to look like, what is everybody doing in terms of a GDP per capita standpoint, as well as just, what are the resulting emissions that are coming out on our pathway moving forward. All of those things you can imagine would have a really big impact on the social cost of carbon, because if you think about damages, if our economy is quite large and has grown a lot, then given events actually might have greater economic damages on it. At the same time, we might be better positioned to actually withstand those damages.
Similarly, like if there are a lot of people, then a given heat wave would have the potential to actually affect more people. So all of that stuff really, really matters. The way that the federal government has approached this problem previously was through the use of a few different scenarios. They actually used five different scenarios of these exact variables: emissions, population, economic growth, and so on. They just said, “we have chosen these scenarios from an exercise that was carried out by the energy modeling forum.” They were in general designs to span the space of uncertainty. There was no suggestion that one of the scenarios was more likely than others, and it was actually just that they all could potentially be equally likely. They had tried to span the uncertainty. And so they averaged across them as they ran the models, according to those scenarios.
By doing so, they were looking to us to span the space. So on the socioeconomic projections, the National Academy of Sciences—as a part of a voluminous set of recommendations that it provided the federal government for improving the estimation methodology of the social cost of carbon—suggested that a few different improvements could be made to those scenarios that have been used before. One fundamental one was to move away from scenarios. It said that actually fundamentally what you would like to have instead of having a bunch of different scenarios that are equally likely would be to have an understanding of what your most likely approach was going to be, and then the uncertainty around that most likely pathway.
So shifting from having discrete scenarios, as you would think about them, to being more like probability densities of these different variables. This is something that's that we've actually undertaken at RFF, to generate these probability densities for the socioeconomics: for economic growth per capita, for population, for energy per unit of economic growth, and also for the carbon intensity of the way that we use energy. By generating these things and putting them all together, you have a probabilistic representation of where we're headed with the socioeconomics.
Kristin Hayes: Clearly you've done a great job of articulating all the thinking that's gone into this number to date. The Biden administration is looking to release a finalized number in January of 2022, as was mentioned earlier. So what happens in between now and then? How do we get from where we are today, where we have this reverting to the 2013 Obama number to that final number that the Biden administration is going to release in about a year?
Kevin Rennert: Yeah, that's a great question. It's clear that the interagency working group has been asked to first come out with these interim estimates and also to steward the updated numbers, and is going to need to lay out what that process looks like. One can imagine that certainly there's going to be a lot of chance for stakeholder input. In the interim estimates there was a note that there will be a Federal Register notice that will have a series of questions on exactly this sort of question. Like, what are the things that they should be thinking about in the process? How should the process look? What are the relevant scientific inputs that should be taken into consideration for this? And so I think that there's going to be a certain amount of response to that.
Then there's going to be a process by which everybody is able to kind of put forward their improvements, and the federal government is going to start to incorporate them into a final number. Clearly, there's even a reference to public comments in the initial executive order. And certainly, this National Academy of Sciences report that I mentioned, I think, is mentioned throughout both the technical support document that was used to support the interim estimates, as well as the executive order. So I think it's really going to be a roadmap for them. A very important piece of that was certainly transparency and also the ability for public comments. So I would imagine that we're talking about a final set of estimates in January 2022. I would certainly imagine that well before that there will be a proposal for what those final estimates would look like that would actually go out and wrap its arms around all these different potential updates that would then be taken into account for the final update.
Kristin Hayes: So get ready, listeners. This is your chance to weigh in on the social cost of carbon. Open for public comment! Anyone who has feelings on discount rates, this is your moment to shine.
Well, Kevin, thank you so much for talking through this very important number and how we get to an updated social cost of carbon. Certainly working with you at RFF, I understand just how much work has gone into this. And so I really appreciate your taking the time to talk through it with me and share your knowledge with our listeners. So let me just close with our regular feature, “Top of the Stack.” I wanted to ask what you have read or watched or heard recently related to the environment that you think is really interesting and that you would recommend to our listeners?
Kevin Rennert: Thanks. It's really been a pleasure to be here talking with you. Thanks so much for having a podcast on the social cost of carbon and giving its moment in the sun and for having me on to talk about it. At the same time that there's all this activity in the federal government to work on the social cost of carbon, which assesses the damages from additional tons of greenhouse gas emissions, there's also a huge effort to think about, well, how would you mitigate those damages? How would you actually reduce emissions?
And so moving the United States to a decarbonized economy is something that I find very, very interesting. I'm working on that side of that, and to get super nerdy here, there was a recent National Academy of Sciences report called “Accelerating Decarbonization of the US Energy System.” This is actually something that a few different RFF affiliates—Sue Tierney, who is on our board, as well as Billy Pizer, who is a university fellow—were involved in the crafting of as part of the National Academy of Sciences committee that put out this report. That's just a fascinating read, because thinking about these complicated challenges as a system, and thinking about the approaches you might take to really decarbonize the way we use energy, is very complex and really interesting and important.
Kristin Hayes: All right. Well, some light bedtime reading. I think it clocks in at several hundred pages if I'm not mistaken.
Kevin Rennert: Yeah these kind of National Academy reports rarely are on the short side.
Kristin Hayes: But, as you noted, chock full of information and really at the heart of how we drive towards a decarbonized economy. So yeah, never a shortage of information to read when it comes to this particular topic. And thanks, Kevin, thank you again for taking the time. I really appreciate it. And couldn't be more timely in terms of our ability to have this conversation just after those interim estimates were released. So I really appreciate it. And I'll talk to you again soon.
Kevin Rennert: Thanks so much, Kristin.
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