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  • Federal Court Supports Use of Social Cost of Carbon

    On August 8, 2016, the Seventh Circuit handed down its opinion in Zero Zone, Inc. v. United States Department of Energy, upholding the agency’s use of the social cost of carbon (SCC) in its regulatory impact analysis of commercial refrigerator energy efficiency standards. The ruling may have paved the way for a new chapter in economically efficient U.S. climate policies, and our brief for the case was acknowledged in the judges’ opinion.

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  • New York State Clean Energy Standard Final Order

    In 2015, New York State announced its Clean Energy Standard, an ambitious mandate to boost clean energy. We have submitted numerous comments to the New York State Public Service Commission, suggesting several changes in the design of this Standard to ensure that the state’s policy goals can be met in the most-cost effective manner. In its final order, the Commission adopted several of our suggested changes. Most notably, the Commission relied on our comments in deciding to calculate zero-emission credit payments based on the Social Cost of Carbon. This marks a major success in our ongoing efforts to encourage government agencies to use the Social Cost of Carbon as a tool when designing policy.

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  • New York State Zero-Emissions Attributes Comments

    We recently submitted comments to the New York State Department of Public Service Staff regarding their Responsive Proposal for Preserving Zero-Emissions Attributes. This Proposal offers recommendations on how to achieve New York’s clean energy target: 50 percent of all electricity used in the state by 2030 should be generated by renewable energy sources.

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  • Comments to SEC on Environmental Disclosures

    We recently submitted comments to the U.S. Securities and Exchange Commission on business and financial disclosures related to environmental risk.

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  • Coal Reform Publications, Workshop for Policymakers

    As the Department of the Interior continues its review of the federal coal leasing program, we recently released two new publications on coal reform and hosted a related workshop for government officials.

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  • Next Steps to Reform the Regulations Governing Offshore Oil and Gas Planning and Leasing Cover

    Next Steps to Reform the Regulations Governing Offshore Oil and Gas Planning and Leasing

    In this Article, we argue that fundamental reform is necessary and highlight a series of key themes and topics that must be addressed to improve the regulatory process and promote better, more consistent management outcomes. While the Article draws on examples from frontier areas-in particular the U.S. Arctic Ocean-the recommended changes would apply to and benefit all areas of the OCS.

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  • Priorities for Federal Coal Reform Cover

    Priorities for Federal Coal Reform

    Twelve Policy and Procedural Goals for the Programmatic Review

    This report highlights twelve policy and procedural recommendations for the review of the federal coal program. These reforms are intended to help modernize program and so that it can provide maximum net benefits to American taxpayers. The programmatic review should identify opportunities to increase revenue, reduce greenhouse gas emissions, and align federal land management with U.S. climate change goals, paying enormous dividends to the public.

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  • Comments on Proposed Offshore Leasing Program for 2017-2022

    We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values.

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  • Legal Pathways to Reducing Greenhouse Gas Emissions Under Section 115 of the Clean Air Act Cover

    Legal Pathways to Reducing Greenhouse Gas Emissions Under Section 115 of the Clean Air Act

    The most efficient legal tool for addressing U.S. climate pollution can likely be found in an unused provision of the Clean Air Act. Section 115 of the Act, titled “International Air Pollution,” authorizes the EPA to develop and implement an economy-wide, market-based program to reduce domestic greenhouse gas emissions. This article, jointly authored by a team of law professors and attorneys at three of the country’s leading institutes focused on climate change and environmental law, offers an in-depth analysis of Section 115, which would provide the most flexible approach for achieving the targets from the Paris climate agreement.

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  • The Bureau of Land Management's Modeling Choice for the Federal Coal Programmatic Review Cover

    The Bureau of Land Management’s Modeling Choice for the Federal Coal Programmatic Review

    There are multiple power sector models available to the Department of Interior (DOI)’s Bureau of Land Management (BLM) for analyzing the effect of current and alternative coal regulations and leasing policies during preparation of its programmatic environmental impact statement (PEIS). This document lays out model selection criteria to assist BLM in weighing the benefits and costs of these available models, and offers recommendations for model selection, highlighting the tradeoff between model complexity and transparency.

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