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Issue Briefs
Understanding EPA’s Enforcement and Compliance Policy During the COVID-19 Pandemic
This issue brief summarizes EPA's enforcement and compliance policy in light of COVID-19, describing its significance and clarifying its contours. The policy opens the door to potentially problematic and harmful actions, especially on a short-term basis.
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Public Comments
Comments to New Jersey BPU on Resource Adequacy Alternatives
The New Jersey Bureau of Public Utilities (BPU) requested public input on its investigation of resource adequacy alternatives. We submitted comments encouraging the New Jersey BPU to recognize important uncertainties affecting the proceeding, consider a broad range of costs of pursuing a Fixed Resource Requirement, and explore the possibility of a carbon pricing program in addition to participation in the Regional Greenhouse Gas Initiative.
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Public Comments
Joint Comments to CTFC on Climate-Related Market Risk
The Commodity Futures Trading Commission (CTFC) requested public input on issues relevant to its Climate-Related Market Risk Subcommittee. We submitted joint comments highlighting the significant financial risks that climate change poses and emphasizing that an economy-wide price on carbon emissions is the regulatory tool that will be the most effective in mitigating a climate-related financial crisis.
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Public Comments
Comments to PHMSA on Data Collection from Pipeline Accidents
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing to gather additional data on pipeline accidents and fires, including data on injuries, property damage, and loss of natural gas. We submitted comments supporting PHMSA’s efforts to better assess the social cost of accidents and encouraging the agency to estimate greenhouse gas emissions that result from pipeline fires.
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Public Comments
Comments to SEC on Regulation S-K and Climate Risk
The Securities and Exchange Commission (SEC) proposed a rule modifying Regulation S-K, which governs reporting requirements for public companies. We submitted comments focusing on the SEC’s failure to require disclosure of risks relating to climate change. Climate risks are economy-wide impacts in which the future increasingly diverges from past experience, and predicting such risks requires more granular data than is typically disclosed in financial reporting. We suggest that the SEC adopt a more specific line-item approach to climate risk reporting, similar to the framework suggested under the Task Force on Climate-Related Financial Disclosures.
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News
New Resource Tracking Reduced Enforcement of Environmental Laws in Response to COVID-19
The Institute for Policy Integrity is tracking altered enforcement of environmental laws by federal and state agencies in response to the COVID-19 pandemic. In connection with the crisis, several agencies have issued waivers or announced plans to stop enforcing key environmental laws and regulations.
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Court Filings
Amicus Brief on EPA’s Clean Power Plan Replacement Rule
Last year, the Environmental Protection Agency (EPA) replaced the Obama Administration’s Clean Power Plan, which sought substantial cuts in greenhouse gas emissions from power plants, with the so-called Affordable Clean Energy (ACE) rule, a far weaker policy that will, at best, yield modest reductions below business-as-usual emissions and, at worst, increase pollution from the electric sector. We filed an amicus brief in the U.S. Court of Appeals for the D.C. Circuit highlighting three key errors in EPA’s rationale for repealing the Clean Power Plan. Specifically, we explain, EPA misstates regulatory precedent and Clean Air Act legislative history supporting the Clean Power Plan and disregards the substantial harms that the ACE Rule will cause.
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Public Comments
Comments to FERC Supporting Petition for Technical Conference on Carbon Pricing
Advanced Energy Economy, the Electric Power Suppliers Association, and a diverse group of other stakeholders recently filed a petition for the Federal Energy Regulatory Commission (FERC) to hold a technical conference on carbon pricing in organized wholesale electricity markets. We have worked extensively to study and promote carbon pricing, publishing a comprehensive report and several academic articles. We also hosted a conference that brought together experts and stakeholders to discuss related legal, economic, and policy questions. Our comments to FERC highlight our previous work on wholesale market carbon pricing and express our support for the requested technical conference.
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Public Comments
Comments to FERC on Lamar County Natural Gas Project
The Federal Energy Regulatory Commission’s (FERC) environmental assessment estimates that the Lamar County Expansion Project would result in 3.87 million metric tons of greenhouse gases from downstream emissions. We submitted comments suggesting that FERC monetize climate impacts using social cost of carbon estimates. The proposed natural gas project would result in over $200 million in annual climate costs.
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Public Comments
Initial Comments to EPA Science Advisory Board on Economic Analysis Guidelines
The Environmental Protection Agency’s chartered Science Advisory Board invited the public to comment on its new draft Guidelines for Preparing Economic Analyses, but made the document available about a week before the comment deadline. We submitted comments suggesting that the SAB hold multiple additional meetings to allow the public to more fully engage on each important topic. We also provided initial responses to the guidelines, noting that they remain the product of thoughtful work grounded in economic literature and offering recommendations for further improvement.
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