November 30, 2023
November 2023 at Policy Integrity
- Policy Integrity Work Shapes New Federal Regulatory Guidance
- How New California and E.U. Requirements Reinforce the Case for the SEC’s Climate-Related Disclosures Rule
- Environmental Justice Technical Assistance Center Goes Live
- “State-Level Pathways to Zero-Emissions Electric Grids” – Conference Recap
- “Industrial Decarbonization Research Insights” – Webinar Recap
- Policy Integrity Staff Honored for Their Work
- We’re Hiring a Legal Fellow! (Deadline Dec. 21st)
- More from This Month
The White House has now finalized its long-awaited revision of Circular A-4, the primary guidance on assessing the costs and benefits of federal regulations. The new guidance represents a major improvement over current practice and incorporates numerous changes that Policy Integrity has long recommended. The new guidance directs agencies to place greater weight on long-term environmental and health benefits through lower discount rates, use robust distributional analysis to break down regulatory impacts along demographic dimensions, and analyze regulatory effects outside the nation’s borders. The final Circular reflects extensive Policy Integrity advocacy. Starting early in the Biden administration, we pushed for revisions of Circular A-4 to endorse lower discount rates and robust distributional analysis. After this update was proposed in April 2023, we organized coalitions of economists and environmental organizations supporting the proposal and suggesting additional reforms. The final Circular incorporates key priorities that we have advanced for years and specific suggestions that we offered during the comment period.
How New California and E.U. Requirements Reinforce the Case for the SEC’s Climate-Related Disclosures Rule
In March 2022, the Securities and Exchange Commission (SEC) proposed a rule that would require SEC registrants to provide climate-related disclosures in their registration statements and annual reports that aligned with the recommendations from the Task Force on Climate-Related Financial Disclosures (TCFD). Since then, other jurisdictions, including California and the European Union, have adopted new climate-related disclosure regimes that also follow the TCFD framework. In a new report, we examine how the California and E.U. requirements may affect the SEC’s cost-benefit analysis of its proposed rule. Overall, we find that the new disclosure regimes do not undermine the economic case for the SEC’s proposed rule; if anything, they bolster it.
We recently celebrated the launch of the Thriving Communities Technical Assistance Center for EPA Region 2. Earlier this year, Policy Integrity was selected by EPA as part of a coalition led by WE ACT for Environmental Justice to create this center, which will provide technical assistance, training, and related support to communities with environmental justice concerns and their partners. The center will also provide training, assistance, and capacity building on writing grant proposals, navigating federal systems such as Grants.gov and SAM.gov, and effectively managing grant funding. At the launch event on October 30th, members of the center’s steering committee discussed some of the services and upcoming trainings that the center will offer. Those interested in receiving assistance can visit the center's new website.
On November 6th, we hosted a conference focused on steps that states can take to build successful and equitable zero-emissions electrical grids. States that have decided to undertake such a transition must figure out how to rapidly bring non-emitting electricity sources onto the grid while also preparing it for the surge in demand that will accompany the electrification of transportation, buildings, and other sectors that currently rely on fossil energy. Researchers and public officials discussed the technical, economic, and equity challenges associated with these goals. The conference also included a keynote address from the Chair of the New York Public Service Commission, Rory Christian. Recordings of each conference panel are available.
This month, Policy Integrity hosted the first in a series of webinars, supported by the Alfred P. Sloan Foundation, focusing on energy and environmental research. The event brought together experts to discuss the multifaceted challenge of decarbonizing key industrial sectors such as steel, cement, and chemical manufacturing. Dr. Erin Mayfield, Dr. Rebecca Ciez, and Simon Mashala explained how their research can help improve high-level decisionmaking, highlight the concerns of workers affected by the transition, and advance research and development efforts in decarbonizing industries. Dr. Avi Shultz, Director of the Department of Energy's Industrial Efficiency and Decarbonization Office, also shared insights on the government's role in industrial decarbonization. Specifically, he noted the importance of government support and investment at all levels of the innovation process, from foundational research to deployment and adoption. All the panelists stressed the need for interdisciplinary research, data sharing, and further research both on emerging technology and its varied impacts. For more in-depth insights, view the webinar recording and read our blog post on key takeaways from the event.
Policy Integrity Staff Honored for Their Work
Two of our attorneys, Al Huang and Jenn Danis, were honored by local groups this month for their work on environmental issues. Al Huang was awarded the Cecil Corbin-Marks Environmental Justice Leadership Award from Clean & Healthy New York, an organization that advocates for a just and healthy society through the elimination of toxic chemicals. Jenn Danis received an award from NY/NJ Baykeeper, a group that works to protect, preserve and restore the ecological integrity and productivity of New York and New Jersey’s Harbor Estuary. All of us at Policy Integrity congratulate Al and Jenn for this well-deserved recognition!
We are seeking applicants for a one- to two-year legal fellowship with a focus on regulatory policy. Legal Fellows at Policy Integrity are assigned projects across a range of substantive areas or may specialize in a key area depending on the fellow’s experience and Policy Integrity’s priorities. In this position, the Fellow will draft amicus briefs, regulatory comments, petitions for rulemakings, and other formal submissions to courts and regulatory agencies. Fellows may also advise other advocacy organizations and supervise the work of NYU Law School students in the Regulatory Policy Clinic. The full job description is available here, and we are looking for applicants who can start in the late summer or early fall of 2024.
We submitted public comments to:
- The Pipeline and Hazardous Materials Safety Administration on proposed pipeline safety initiatives aimed at preventing incidents like the catastrophic 2018 gas pipeline explosions in Merrimack Valley, Massachusetts.
- EPA on a proposal to limit emissions from reclassified major sources of air toxics by withdrawing the “Once-In Always-In Rule.”
- BLM on a supplemental environmental impact statement considering the impacts of an upcoming lease sale in the Arctic National Wildlife Refuge.