April 1, 2016
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Improving Offshore Leasing
We recently helped bring about a critical policy change that will affect the way offshore fossil fuel resources are leased. The Department of the Interior’s (DOI’s) new offshore leasing program makes use of an economic approach we have repeatedly advocated for. Since 2009, we have used academic scholarship, frequent public comments, and a federal lawsuit to encourage DOI to factor in the social and environmental costs of drilling, and account for “option value,” a common financial concept that places value on delaying irreversible decisions in order to gain more information. DOI’s new leasing plan makes use of many of our recommendations. Among other highlights, the agency will now consider environmental and social costs in the “hurdle price” analysis that helps determine whether lease sales should proceed. This will likely affect leases in sensitive areas like the Arctic. Our fingerprints are evident throughout the proposed plan, and we continue to push for related reforms in DOI’s offshore program as well as its onshore coal, oil, and gas programs.
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New Brief in Clean Power Plan Case
Last week, we filed an amicus brief in the litigation over the EPA’s Clean Power Plan. The plan’s opponents have based their legal argument on the core assertion that the rule is “unprecedented.” But our brief shows that every major element of the Clean Power Plan that opponents say is unprecedented has in fact been used by the EPA before, under administrations of both parties. Our analysis of prior EPA rules and relevant court decisions—some dating back to the Reagan administration—reveals that the structure of this rule is consistent with decades of Clean Air Act practice.
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Legal Landscape Updates, Al Jazeera America/New York Times
We recently launched a new series of monthly email updates on the legal issues surrounding the Clean Power Plan. You can subscribe to these “Legal Landscape” updates here. Our first update focused on recent Supreme Court developments as well as a new op-ed from Richard Revesz that discusses the effects of the Supreme Court’s stay ruling on the Clean Power Plan’s timeline and EPA’s current work. Al Jazeera America also recently profiled Policy Integrity’s efforts to support the Clean Power Plan in a primetime news segment, and Revesz spoke to the New York Times about the rule.
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Comments on FDA Proposal to Restrict Artificial Tanning
We recently submitted comments in response to the Food and Drug Administration’s (FDA’s) proposed rule to restrict the use of sunlamps for artificial tanning. We concluded that although the proposed rule takes a significant step in reducing the risks of artificial tanning, the FDA should strengthen the justification for this proposed rule. In particular, we recommend that the FDA use more sensible assumptions related to a proposed risk acknowledgment form; consider the negative externalities that accompany sunlamp use to avoid overestimating the consumer welfare loss from the restriction; fully account for the health benefits of restricting sunlamp use; avoid underestimating the habit effect by considering the addictive qualities of tanning; and account for existing state regulations to ensure an accurate assessment of the proposed rule’s costs and benefits. The project was undertaken in honor of Kelly Cosby, one of our former Clinic students, who passed away in November after a brave battle with advanced melanoma.
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Alumni Spotlight: Valerie Stahl
Valerie Stahl is the former Associate for Development, Events, and Operations at the Institute for Policy Integrity, where she headed fundraising and logistical efforts. She has continued to manage a Policy Integrity project, which assesses the distributional effects of the National Flood Insurance Program. In 2014, she left the organization to pursue her Ph.D in Urban Planning at Columbia University. Her research broadly focuses on the impacts of housing, neighborhood composition, and land-use decisions on communities in NYC. “Beyond developing the valuable skills of grant-writing and conference production,” Stahl said, “my time at Policy Integrity influenced how I think about long-term planning and taught me the importance of mobilizing cost-benefit analysis in defense of critical public goods.”