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  • Should EPA Bow To Chamber’s Demand?

    September 1, 2009 – The National Journal’s Energy and Environment Experts Blog

    EPA should not grant the Chamber of Commerce’s request for an extraordinary on-the-record proceeding concerning the agency’s expected endangerment finding. Rather than engage in this time consuming process of little value, the agency should move forward with much needed regulatory action that was grossly delayed by the political calculation of the last administration, even as the science connecting greenhouse gas emissions to severe environmental consequences has continued to mount.

  • Putting The “benefit” Back In Cost-benefit Analysis

    July 23, 2009 – The New Republic’s The Vine Blog

    The climate-change bill that passed the House last month and is currently being considered by the Senate represents America’s last chance to seriously address its contributions to global warming before we head to the international climate talks in Copenhagen this December. But the current legislative debate also offers an opportunity to reshape the broader conversation over the costs and benefits of environmental regulation—and environmentalists should not let the opportunity pass them by.

  • Livermore quoted on changes to EPA’s CBA guidelines (sub. req.).

    July 21, 2009 – Inside EPA’s Risk Policy Report

    The Institute for Policy Integrity (IPI) at New York University, which generally supports expanded use of cost-benefit analysis, applauded the changes to the guidelines, and also pointed out that the SAB encouraged the use of cost-benefit analysis when looking at deregulatory or non-regulatory proposals. A source with the IPI says that, during the last administration, economic analysis was not conducted for many deregulatory actions, including changes to the new source review rules, which require new or modified sources to install strict pollution controls. The source says it is “important that the SAB realized the systemic problem about how cost-benefit analysis has been used in the past” by pointing out the need for analysis for deregulatory actions.

  • The three things Cass Sunstein should do on his first day

    July 16, 2009 – Grist

    As I’ve mentioned before, Sunstein’s appointment is pivotal for environmental regulation and green advocates should be looking forward to his first official day on the job. His inbox is probably overflowing with tasks, but here are the top three that he should work on first.

  • Advisers urge stronger climate focus in regulation analyses

    July 14, 2009 – ClimateWire

    The board also recommends that the agency better account for technological innovation when estimating the costs of compliance, according to Michael Livermore, executive director at New York University’s Institute for Policy Integrity, who read its draft. Typically, said Livermore, EPA inflates compliance costs, because it does not account for industries’ motivation to innovate once actually faced with costly restrictions.

  • Advisers urge agency to revamp regulatory analysis

    July 13, 2009 – E&E News PM

    Michael Livermore, executive director of New York University’s Institute for Policy Integrity, said he expects the Obama administration to ultimately adopt most, if not all, of the science advisory board’s recommendations. “I’d be surprised if they disagreed with the [Science Advisory Board],” he said. The full board is expected to consider the draft report in August before sending its final comments to EPA.

  • Low-profile changes at EPA could have major environmental impacts.

    July 13, 2009 – Environmental Valuation & Cost-Benefit News

    EPA has been quietly working on some serious changes to the guidelines it uses to conduct cost-benefit analysis. Tweaks to the powerful but low-profile Guidelines for Preparing Economic Analyses could have major impacts on the environment. The Guidelines is little known outside of EPA, but is used in the design of every major environmental regulation.

  • Here Comes the Sunstein: Cass Sunstein Takes Over as Regulatory Czar

    July 1, 2009 – Inside Counsel

    “The fact that he’s not a stereotype is definitely a good thing, both for public health and the environment and for businesses,” says Michael Livermore, executive director of the Institute for Policy Integrity at New York University’s School of Law. “If you fit him in the stereotype, he’s either going to be bad for business or bad for the environment, and that’s not a choice we want to have to make. He’s going to be looking to make sure we achieve our environmental public health goals in a way that gives companies maximum flexibility to achieve our social goals at the lowest possible costs.”

  • Sotomayor’s “Green” Decision

    May 28, 2009 – Huffington Post

    Judge Sonia Sotomayor’s paper trail on the environment is slim, but one decision has drawn praise from environmentalists, and some concerns from business. In Riverkeeper v. EPA, Sotomayor wrote the opinion for the court of appeals. She found that the Clean Water Act prohibited EPA from conducting cost-benefit analysis when deciding whether to impose regulations at power plants that would protect fish, but have high costs for utility companies.

  • Murky reg-review process set stage for frenzy over OMB memo

    May 14, 2009 – Greenwire

    OMB and its regulatory review office are walking a fine line on transparency, said Michael Livermore, executive director of New York University’s Institute for Policy Integrity. “It’s a good thing to have the public being able to be responsive to these kinds of interagency discussions,” Livermore said. But if agencies had to take full responsibility for anything they said, it could have a “chilling effect,” he added.