Institute for Policy Integrity

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Project Updates

Viewing all updates in Climate Change and Energy Policy
  • Public Comments

    Comments on Reconsideration of NHTSA Rule to Update Civil Penalties

    October 10, 2017

    In December 2016, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that updates civil penalties for car manufacturers that violate fuel economy standards. NHTSA is now reconsidering the rule, claiming it would have a significant negative economic impact. The agency provides no evidence that economic circumstances have changed since the rule’s finalization to make the rule more costly. Our comments argue that the agency should not proceed with the proposed reconsideration, because it inadequately explained why it changed positions. If the agency does continue with the reconsideration, both the Inflation Adjustment Act and economic cost-benefit analysis would justify an update to the penalties rates rather than maintaining the original penalty rate from 1975.

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  • Public Comments

    Reconsideration of GHG Emissions Standards for Model Year 2022-2025 Light-Duty Vehicles - Comments

    October 10, 2017

    In August, Environmental Protection Agency and National Highway Traffic Safety Administration announced their intentions to reconsider greenhouse gas and fuel economy standards for light-duty vehicles for model years 2022-2025. Our comments show that the employment effects from the standards are likely to be small, and we provide details on the short comings and biases of industry analyses that purport to show large employment effects. In contrast, the comments explain that the standards will help reduce numerous externalities, resulting in large welfare gains for consumers and the creation of valuable environmental benefits.

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  • Public Comments

    Comments to Interior’s Royalty Policy Committee

    October 9, 2017

    On behalf of Policy Integrity, Policy Director Jayni Hein recently delivered a statement at the Department of Interior’s Royalty Policy Committee public meeting on October 4, 2017. Her statement included recommendations on how Interior can achieve “fair market value” for taxpayers for the use and development of federal resources, as well as how Interior can fulfil its “multiple use” mandate.

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  • Public Comments

    Joint Comments on Fuel Economy Standards and the Social Cost of Greenhouse Gases

    September 25, 2017

    Vehicle fuel economy standards set by the National Highway Traffic and Safety Administration (NHTSA) help reduce greenhouse gas emissions in the United States by making cars more fuel efficient. Our comments on the reconsideration argue that NHTSA should value the social cost of those emissions as robustly as possible, as they have done in the past. We encourage NHTSA to consider the social cost of greenhouse gases in both the rule’s Environmental Impact Statement and Regulatory Impact Analysis, and that it should use estimates considering global damages of climate change using a three percent or lower discount rate.

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  • News

    Response to a Critique of New York State’s Clean Energy Programs

    September 20, 2017

    A recent report criticizing New York’s Clean Energy Standard (“CES”) incorrectly argues that the CO2-reduction benefits from these programs are non-existent. The report claims that the benefits of reducing CO2 emissions with the CES, which are valued using the Social Cost of Carbon (“SCC”), are “effectively zero.” This conclusion and the preceding assertions are incorrect and inconsistent with basic economics. Our response highlights the flaws of the report and explains that New York’s CES in fact generates significant and crucial environmental benefits.

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  • News

    Court Rules Against Bureau of Land Management’s Inadequate Consideration of Climate Effects

    September 15, 2017

    On September 15, 2017, the U.S. Court of Appeals for the 10th Circuit ruled that the Bureau of Land Management (BLM) violated the National Environmental Policy Act (NEPA) by providing an inadequate analysis of the likely climate impacts from four coal leases. This ruling, as argued in our press release on the case, establishes an important judicial precedent. Agencies cannot make unsupported assumptions about climate effects while still complying with NEPA and the Administrative Procedure Act.

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  • Court Filings

    Amicus Brief on Bureau of Land Management’s Waste Prevention Rule

    September 7, 2017

    The Bureau of Land Management’s (BLM’s) Waste Prevention Rule, enacted on November 18, 2016, sought to prevent oil and gas companies from wasting natural gas produced on public land. In June 2017, BLM stayed the rule by indefinitely postponing key compliance deadlines. In response, the states of California and New Mexico as well as several environmental organizations filed suit against BLM in the U.S. District Court for the Northern District of California. In our amicus brief in support of the plaintiffs, we argue that BLM failed to provide a reasoned explanation for the stay, as required by the Administrative Procedure Act, because BLM ignored the forgone benefits of the Waste Prevention Rule.

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  • Public Comments

    Public Comments on Regulatory Review (Treasury, GSA, FEMA, State, DOJ, FCA, Interior)

    August 15, 2017

    Many federal agencies are requesting the public’s suggestions for rules to repeal or reform, tacitly implying that most regulations stifle economic growth. In comments to several agencies, we argue that regulatory review should consider the public benefits of regulation, not just the costs to regulated industries, and should prioritize review of rules for which actual costs and benefits diverge significantly from predicted costs and benefits.

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  • Public Comments

    Comments to EPA on Delaying Methane Rule

    August 9, 2017

    In 2016, EPA issued a rule to decrease methane and volatile organic compound emissions from new, modified, and reconstructed sources in the oil and natural gas sector. EPA has now proposed to suspend some of the rule’s compliance obligations for two years while the agency decides whether and how to revise those requirements. The U.S. Court of Appeals for the D.C. Circuit rejected an earlier attempt by EPA to stay the methane rule for 90 days, and our comments argue that the new proposal is similarly unlawful.

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  • Public Comments

    Comments to Minnesota on the Social Cost of Carbon

    July 31, 2017

    The Minnesota Public Utility Commission (PUC) updated its social cost of carbon (SCC) values last week to a range of approximately $9 to $43, drawing from the 2015 Interagency Working Group (IWG) estimates. Minnesota’s use of the IWG SCC values recently came under scrutiny by industry groups in the state, who cited the recent energy executive order as reason to revisit the PUC externality estimates. After initial oral arguments, parties were invited to submit revised SCC values. Accordingly, we shared our recent comments to the U.S. Army Corps of Engineers, along with a cover letter explaining the importance of our analysis to the PUC.

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