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Comments to EPA on Cross-State Air Pollution Rule
Public Comments / December 14, 2020 / DownloadOur comments on the Revised Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS identify critical flaws in the proposal's design and regulatory impact analysis. The Environmental Protection Agency's (EPA) unreasonably low valuation of climate effects also contributes to its selection of an inefficient policy alternative. We submitted joint comments detailing how EPA's flawed analysis harms public health and the environment.
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Building a New Grid Without New Legislation
A Path to Revitalizing Federal Transmission Authorities
In the absence of legislation, critical long-distance transmission can be developed by applying existing federal legal authorities. A number of important regulatory and commercial measures have been proposed, including streamlining transmission planning, upgrading existing transmission system components, putting transmission lines underground, and using existing rights-of-way from highways and railroads. Even if these solutions are adopted, however, state siting requirements may prove an important obstacle to developing an efficient, national transmission grid. So, this paper examines legal authorities already available to the Department of Energy and the Federal Energy Regulatory Commission to develop the interstate transmission capacity crucial to the energy transition.
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Amicus Brief in D.C. Circuit on Methane Limits for Oil and Gas Sector
Court Filings / December 14, 2020 / DownloadThe Environmental Protection Agency (EPA) recently finalized revisions to New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector. We filed an amicus brief in the U.S. Court of Appeals for the D.C. Circuit, focusing on EPA's flawed legal and economic justifications for the rule.
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Report Series: the Flawed Analysis Underlying the Rollback of the Clean Car Standards
The Environmental Protection Agency and National Highway Traffic Safety Administration used several gimmicks and faulty assumptions to skew the analysis of the rollback rule, obscuring just how harmful it is to the American public. We published a series of reports examining several of the flaws.
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Comments and Reply Comments on FERC’s Carbon Pricing Policy Statement
Public Comments / December 1, 2020 / DownloadThe Federal Energy Regulatory Commission proposed a policy statement on carbon pricing in organized wholesale electricity markets. We submitted comments encouraging FERC to strengthen its proposal by making specific clarifications. We later submitted reply comments addressing points made by other commenters and providing further guidance on how FERC can improve its final policy statement.
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Turbocharged
How One Revision in the SAFE Rule Economic Analysis Obscures Billions of Dollars in Social Harms
This report is part of a series that documents how the assumptions underlying The Safer Affordable Fuel Efficient (SAFE) Vehicles Final Rule for Model Years 2021–2026 Passenger Cars and Light Trucks are skewed to make the rule look less harmful than it actually is. In this report, we focus on the rule’s estimate of vehicle sale price elasticity, which substantially inflates the rollback’s effect on new vehicle purchases.
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Comments to New York DEC on the Value of Carbon
Public Comments / November 27, 2020 / DownloadNew York State's Department of Environmental Conservation (DEC) has adopted a damage-cost approach to valuing carbon dioxide pollution. We submitted comments on the DEC's draft guidance supporting the policy. Our comments also raise points about the appropriate use of discount rates, calculating damages for other greenhouse gases, inclusion of co-benefits in analysis, and further considerations for a marginal abatement cost approach.
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Amicus Brief in Ninth Circuit on Montana Coal Mine Expansion
Court Filings / November 20, 2020 / DownloadThe expansion of the Bull Mountains Mine project in Montana would allow for an increase in coal production likely resulting in more than $9 billion in climate damages. We filed an amicus brief in the U.S. Court of Appeals for the Ninth Circuit criticizing the Office of Surface Mining’s analysis of the project, which fails to monetize climate impacts using the social cost of carbon. We explain that the project’s full economic benefit is, at most, just one-third of its expected climate costs.
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Harmonizing States’ Energy Utility Regulation Frameworks and Climate Laws
A Case Study of New York
Unless the institutional framework and laws pertaining to fossil fuels are modified appropriately, decarbonization efforts will likely be stymied by confusion and related opportunities for opposition. This article, published in the Energy Law Journal, aims to start a wider conversation about the process of conforming existing energy law with novel, climate-oriented legislation. We concentrate on New York’s situation to illustrate how these tensions can manifest and what might be done to address them.
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Overinflated
The SAFE Rule’s Overstated Estimates of Vehicle-Price Impacts
This report is part of a series that documents how the assumptions underlying The Safer Affordable Fuel Efficient (SAFE) Vehicles Final Rule for Model Years 2021–2026 Passenger Cars and Light Trucks are skewed to make the rule look less harmful than it actually is. In the SAFE Rule, the Environmental Protection Agency and the National Highway Traffic Safety Administration have significantly rolled back the greenhouse gas emission and fuel economy standards for light vehicles established under the Obama Administration. This report highlights three critical problems in the agencies’ assumptions about vehicle prices.
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