-
Comments on the Consideration of Climate Benefits in Proposed Rule to Limit Methane Leakage from Gas Pipelines
In May, the Pipeline and Hazardous Materials Safety Administration released a draft regulation to prevent methane leaks from gas pipelines. The agency monetized the climate benefits of the regulation using the social cost of methane, finding that monetized benefits exceeded monetized costs by at least $340 million per year. In our comment letter, we support the agency for applying the social cost of greenhouse gases to estimate the climate benefits of the proposed rule. We also suggest that PHMSA apply additional analysis to each rule using draft updated climate-damage valuations that the Environmental Protection Agency released in November 2022.
-
Comments to EPA on Proposed Emissions Standards for New Motor Vehicles
In May 2023, EPA proposed to strengthen tailpipe emissions standards for greenhouse gas and criteria pollutants for both light-duty and medium-duty vehicles. The standards apply to vehicle model years beginning in 2027 and would increase in stringency through model year 2032. In our comment letter, we explain that the Proposed Rule represents a sensible approach to cost-effectively reducing motor vehicle pollution that contributes to climate change and harms public health. We suggest that EPA take some additional steps to robustly support the regulation and ensure a complete presentation of benefits and costs.
-
Comments to EPA on Proposal to Strengthen the Mercury and Air Toxics Standards
In April 2023, the Environmental Protection Agency (EPA) proposed to strengthen and update the National Emission Standards for Hazardous Air Pollutants for coal- and oil-fired power plants, also known as the Mercury and Air Toxics Standards (MATS). In this proposal, EPA clearly explained why it revised the technology review conducted in 2020 and made the emissions standards more stringent on the basis of developments in control technologies. In our comments, we recommended improvements to the proposed update and highlighted areas where EPA's analysis succeeded. -
Comments to EPA on Proposed Rule to Strengthen Power Plant Effluent Guidelines
In March, the Environmental Protection Agency (EPA) proposed to strengthen its power plant effluent guidelines by tightening discharge requirements for flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate resulting from steam electricity generation. In our comment letter, we offer several recommendations for EPA to strengthen its consideration of regulatory benefits.
-
Comments to the CPSC on Chronic Hazards Associated with Gas Ranges and Proposed Solutions
In March 2023, the Consumer Product Safety Commission (CPSC) published a Request for Information on Chronic Hazards Associated with Gas Ranges and Proposed Solutions. We submitted comments which highlighted the major findings from our report. We explained how the CPSC could regulate gas ranges and recommened possible futher actions.
-
EPA Restores Legal Foundation to Limit Mercury & Air Toxics from the Power Sector
This month, EPA restored the legal foundation for regulating emissions of mercury and other hazardous air pollutants (HAPs) from coal- and oil-fired power plants under section 112 of the Clean Air Act. Policy Integrity has long recommended that EPA adopt such an approach that considers unquantified and ancillary effects, as is consistent with the best economic practices and the law, including through our comments on the 2022 proposed rule and an amicus brief opposing the 2020 finding.
-
Targeted Regulation for Reducing High-Ozone Events
Working paper
Nitrogen oxides (NOx) are a precursor to ground-level ozone, a pernicious pollutant that is harmful to human health and ecosystems. Despite decades of regulations and a sharp decline in NOx emissions, episodic high-ozone events prevent many areas from attaining air quality standards. Theoretically, spatially or temporally differentiated emissions prices could be more cost effective at reducing such events than a uniform price. To test this prediction, with data from EPA and NOAA spanning 2001–2019, this working paper uses novel empirical strategies to estimate (1) the link between hourly emissions and high-ozone events and (2) hourly marginal abatement costs. These estimates form the basis for simulations that compare uniform and differentiated emissions pricing. Consistent with economic theory, differentiated pricing is substantially more cost effective at reducing high-ozone events, but this advantage depends on the accuracy of the estimated NOx–ozone relationship.
-
Still Your Grandfather‘s Boiler: Estimating the Effects of the Clean Air Act‘s Grandfathering Provisions
Working paper
While vintage differentiation is a highly prominent feature of various regulations, it can induce significant biases. We study these biases in the context of New Source Review—a program within the US Clean Air Act imposing costly sulfur dioxide (SO2) abatement requirements on new boilers but not existing ones. In particular, we empirically investigate how the differential treatment of coal boilers shaped the generation landscape by affecting unit utilization, retirement, and emissions. Focusing solely on the additional SO2 emissions, we estimate annual costs of up to $65 billion associated with the vintage differentiation in New Source Review.
-
Air Pollution and Environmental Justice
Published in Ecology Law Quarterly
The article examines the failures of the U.S. Environmental Protection Agency to address the environmental justice harms from air pollution and identifies three recent development that could augur beneficial change.
-
Comments to EPA on its Proposed Asbestos Risk Management Rule
The Environmental Protection Agency (EPA) has proposed a ban on multiple conditions of use of chrysotile asbestos. The Institute for Policy Integrity and Professor Rachel Rothschild at the University of Michigan Law School submitted comments on the agency’s economic analysis of the proposed rule, identifying numerous ways EPA underestimated the health benefits from reduced cancer cases and lung illnesses and could strengthen the robust scientific, economic and legal basis for EPA’s proposed rule.
Viewing recent projects in Environmental Health