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Letter to EPA on water quality permitting
Policy Integrity submitted a letter to the EPA on its upcoming rulemaking regarding water quality permitting. The letter makes recommendations on improving the efficiency of EPA’s implementation and enforcement of the Clean Water Act.
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Letter to BOEM regarding options value
Currently, the federal government treats lease sales as a now-or-never decision. That’s an approach that leads to too many leases sold too quickly, at too low a price. Instead, BOEM should be waiting to sell these leases until the time is right—when they can get the highest possible price.
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Patience is a(n Economic) Virtue
Real Options, Natural Resources, and Offshore Oil
Consideration of real options is necessary to maximize economic return from non-renewable natural resource extraction. But ecisions over drilling are often framed as a now-or-never choice, so the option to wait (or “real option” value) is improperly treated in administrative processes that determine whether, when, and how offshore oil resources will be tapped.
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Launch of Energy Tax Breaks Wiki
Policy Integrity recently launched a wiki aimed at providing a better understanding of how energy sectors are subsidized by the tax code. The wiki will gather the expertise of lawyers, economists, tax professionals, and concerned citizens to catalog tax breaks received by the fossil and renewable energy industries.
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BOEMRE Responds to Policy Integrity’s Petition
The Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) recently responded to our petition to reconsider its leasing policies. They commit to further review of our recommendations and mention the possibility of incorporating our findings in the next 5-year leasing program.
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Comments to EPA on Proposed Cooling Rules
Policy Integrity submitted comments to the EPA on its proposed rules for cooling water intake structures, required under the Clean Water Act. These rules would affect practices at power plants that mean death for thousands of fish boiled or pinned by screens and intake pipes.
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Petition to BOEMRE on Option Value
This morning, Policy Integrity petitioned the Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) to reconsider its leasing policies, which may encourage over-drilling. The topic is the Outer Continental Shelf Lands Act’s (OCSLA) requirement of the Secretary of the Interior to develop five-year schedules that specify the timing for offshore leasing activity.
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The BP Gulf Coast Oil Spill, Option Value and the Offshore Drilling Debate
One year after crude oil began gushing into the Gulf of Mexico, little action has been taken to prevent a similar disaster. A report authored by Gaia Larsen and Michael A. Livermore finds that overly simplistic economic analysis by the government may have helped lead to the accident.
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Comments to Agencies on Retrospective Review
In addition to submissions to the Department of Energy and the Environmental Protection Agency, Policy Integrity also sent our recommendations on developing policies for conducting retrospective reviews to fourteen additional agencies this week, including the Department of the Interior (DOI), the Department of Justice (DOJ), the Small Business Administration (SBA), and the State Department.
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Residual Risks
The Unseen Costs of Using Dirty Oil in New York City Boilers
In about 9,000 big apartment and commercial buildings in Manhattan, Brooklyn, Queens, and the Bronx, boilers burn a dirty fuel to heat their units. “Residual Risks” analyses the health, environmental, and economic benefits of switching away from this dirty fuel to cleaner alternatives like natural gas.
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