November 30, 2021
November 2021 at Policy Integrity
- How a Carbon Trading Program Could Green NYC Buildings
- Policy Integrity Is Hiring!
- Federal Agencies’ Role in Adapting to Climate Change
- New Commentary: A Methane Breakthrough; Major Questions Doctrine
- Cost-Benefit Analysis, Immigration Edition
- Staff Spotlight
- More From This Month
Policy Integrity collaborated with other NYU researchers to examine whether New York City should consider adopting a carbon trading program for its buildings, in line with its landmark 2019 mandate to reduce building emissions, Local Law 97. The study offered two proposals for trading programs and found that both would lead to deeper greenhouse gas reductions and lowered costs of complying with LL97. Moreover, both proposals would benefit the city as a whole and environmental justice communities in particular.
We are currently hiring for a senior colleague to help lead our work on environmental justice, climate justice, and energy justice. The position will focus on analysis of the distributional impacts of environmental and energy policies and related advocacy efforts. Read the job description here – applications are due by December 5, 2021!
We also have a vacancy for a postdoctoral research fellow in economics. The ideal candidate will have a focus on policy-oriented research in either environmental or resource economics, transportation and vehicle emissions policy, or utility regulation and electricity markets. The job description is available here, and applications are due by January 5, 2022.
As part of its whole-of-government approach to climate change, the Biden administration recently issued Federal Agency Climate Adaptation and Resilience Plans. We submitted joint comments with our Initiative on Climate Risk and Resilience Law partners, in which we recommend that agencies publicly disclose the climate risks they face, examine the greenhouse gas emissions impacts of adaptation, and study and disseminate information about best practices for adaptation measures.
In a Slate opinion piece, Jack Lienke and Richard Revesz explain why EPA’s new rule to limit methane is so significant: by applying to old and new facilities alike, it avoids an error that has undercut agency initiatives for five decades. The rule will cover hundreds of thousands of previously unregulated sources, such as wells, storage tanks, and compressor stations.
In a recent Regulatory Review piece, Natasha Brunstein and Richard Revesz examine abuses of the “major questions” doctrine, which anti-regulatory groups use to advocate that certain limits on greenhouse gas emissions must be decided by Congress rather than agencies. For example, Brunstein and Revesz explain why the Trump-era practice of using the number of comments a proposed rule receives to determine “major question” status must be rejected.
Policy Integrity has long supported the use of cost-benefit analysis in crafting environmental rules, but the tool can be applied to a much broader range of issues—including immigration. Our team recently submitted comments to the Department of Homeland Security on its proposal to keep Deferred Action for Childhood Arrivals (DACA) in place, outlining how the agency could strengthen the cost-benefit analysis underlying its regulation. Among other steps, we recommended that the agency quantify and monetize DACA’s beneficial mental and physical health impacts on program beneficiaries and their children to strengthen its justification for the rule.
This month, Legal Director Jason Schwartz took a leave to become a Senior Adviser at the Office of Information and Regulatory Affairs. Jason is the latest member of our team to enter the Biden administration, joining Jayni Foley Hein (White House Council on Environmental Quality), Burçin Ünel (Department of Energy), and Avi Zevin (Department of Energy).
In other exciting news, our former development and operations associate Valerie Stahl started work as an Assistant Professor at San Diego State University, having recently completed her PhD in urban planning at Columbia University. Her research and advocacy focus on affordable housing, community development, and zoning.
We submitted comments to:
- EPA on incorporating environmental justice into its Draft Strategic Plan for 2022-2026
- The Council on Environmental Quality on proposed revisions to NEPA Regulations
- The Federal Insurance Office on reducing climate risk in insurance markets
- FERC in response to other comments on its transmission ANOPR
- The Department of Health & Human Services on the repeal of Trump-era Good Guidance Practices Rule
We also co-hosted a webinar on diversity, equity, and inclusion in environmental government jobs with the State Energy and Environmental Impact Center.