Policy Integrity, along with Environmental Defense Fund, Natural Resources Defense Council, and Union of Concerned Scientists, submitted comments on the social cost of carbon (SCC) within a rule proposed by the Department of Energy regarding energy conservation for commercial refrigeration equipment. The SCC calculation is an estimate of the damage caused by each ton of carbon emissions and used in the cost-benefit analyses of regulations with greenhouse gas emissions reductions.
Our comments support DOE’s use of the government SCC measure and the transparency of the process. The group also noted that current SCC values are likely underestimates and that this should be addressed in future updates.
On Oct 21, 2013, Policy Integrity, along with the above organizations, submitted similar comments to DOE on the SCC regarding energy conservation from metal halide lamp fixtures. The comments said that economic research shows the estimate used by the government may be too low. In addition, the group submitted comments on a petition for correction filed by industry groups to the Office of Management and Budget (OMB) and other agencies. The group urged the OMB to deny industry groups’ request to prohibit use of the social cost of carbon. The comments said the industry groups’ petition is based on erroneous arguments and that the government used proper models and statistical methodologies.
Prior to that, in 2011, Policy Integrity along with five other organizations sent a letter to senior U.S. government officials urging the Administration to fulfill its commitment to update the SCC to reflect improving science and economic understanding of climate change and its impact.
Policy Integrity, on behalf of the Washington, D.C.-based Center for Sustainable Economy, filed the opening brief in a lawsuit to halt illegal practices at the Bureau of Ocean Energy Management. The brief argues that incomplete and flawed economic analysis leads BOEM to sell new offshore leases too quickly and too cheaply, potentially costing the American public hundreds of billions of dollars.
Currently, America’s energy needs are being met, the vast majority of previous leases remain idle, and the U.S. has become a major exporter of petroleum and gas products. These factors make deepwater oil deposits far more valuable in the future. According to administrative law, the government must incorporate these considerations into its lease-sale decisions, including the option of deferred leasing.
The lawsuit was filed in the United States Circuit Court for the District of Columbia and will be argued next year.
In 2012, Policy Integrity sent a letter to BOEM along with Michael Livermore’s working paper, Patience is a(n Economic) Virtue requesting that the agency incorporate options value into their assessments of offshore drilling lease sales.
Policy Integrity, along with the Environmental Defense Fund, the Natural Resources Defense Council, and the Union of Concerned Scientists, submitted comments on the social cost of carbon. The calculation—an estimate of the damage caused by each ton of carbon emissions—was used in a rule proposed by the Department of Energy regarding energy conservation from metal halide lamp fixtures. The joint comments show that according to cutting-edge economic research, the estimate used by the government may be too low.
The group also submitted comments on a petition for correction filed by industry groups to the Office of Management and Budget (OMB) and other agencies. The industry groups’ request to prohibit the use of the social cost of carbon is based on erroneous arguments and our comments urge the OMB to deny the petition. We find that the government used the proper models and statistical methodologies to estimate damages of climate change and the benefits of emission reduction.
In 2011, Policy Integrity along with five other organizations sent a letter to senior U.S. government officials urging the Administration to fulfill its commitment to update the SCC to reflect improving science and economic understanding of climate change and its impact.
Today, Policy Integrity filed an amicus brief with the Supreme court which argues that in place of an established, relatively unchallenged understanding of EPA authority, a lower court substituted its preferred policy for that of the agency. In doing so, it acted inconsistently with core principles of American administrative law.
This case, which challenges EPA’s cross-state air pollution rule, reaches the nation’s highest court after a lower court set aside three decades-worth of consistent agency interpretation of the Clean Air Act by six administrations of both political parties, to disallow EPA from using market mechanisms to reduce the amount of dirty air flowing across state borders.
Most economists agree that market mechanisms are the best way to cut pollution. They do so cheaply and effectively. The D.C. Circuit’s decision makes using them in the case of interstate air pollution difficult if not impossible. The consequences of the Supreme Court allowing the decision to stand would be either the more expensive, more cumbersome command-and-control regulatory action the D.C. Circuit prescribed, or a stalling out of the rule altogether. Both scenarios will result in dirtier air and leave 34,000 lives at risk each year.
For more background on CSAPR, click here.
The President’s Council on Environmental Quality (“CEQ”) has implemented several changes to the Proposed National Objectives, Principles and Standards for Water and Related Resources Implementation Studies that are consistent with recommendations Policy Integrity made in comments on the 2009 draft.
We sent this letter acknowledging CEQ’s work to clarify how federal agencies should approach selecting a baseline, employing an appropriate discount rate, and valuing non‐market goods when possible. We also commend CEQ’s discussion of the importance of transparency in the decisionmaking process, as well as its effort to refer agency decisionmakers to relevant resources for conducting their cost‐benefit analyses.