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  • Ensuring Robust Consideration of Climate Change Under NEPA Cover

    Ensuring Robust Consideration of Climate Change Under NEPA

    Six Priorities for CEQ’s Phase 2 Rulemaking

    In April 2022, the Council on Environmental Quality (CEQ) finalized a limited, “Phase 1” rulemaking to restore several longstanding features of the regulations that guide agency assessments under the National Environmental Policy Act (NEPA) which CEQ had removed in 2020. In that rule, CEQ reaffirmed its intentions to further revise the regulations to better ensure that agencies make decisions that “advance environmental, climate change mitigation and resilience, and environmental justice objectives.” This policy brief outlines six simple regulatory revisions that CEQ should prioritize for its “Phase 2” rulemaking to improve consideration of climate change during environmental review.

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  • The Emissions in the Kitchen Cover

    The Emissions in the Kitchen

    How the Consumer Product Safety Commission Can Address the Risks of Indoor Air Pollution from Gas Stoves

    Gas stoves are found in over a third of American homes, and these appliances generate dangerous indoor levels of nitrogen dioxide (NO2) and fine particulate matter (PM2.5) within just a few minutes of cooking. This report suggests several ways the Consumer Product Safety Commission (CPSC) can and should take action to address the unreasonable health risks posed by gas stove emissions.

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  • Reforming Pipeline Review Cover

    Reforming Pipeline Review

    Taking a Closer Look at the Need for New Natural Gas Infrastructure

    The Federal Energy Regulatory Commission (FERC) uses a flawed process to evaluate the need for new, long-lasting gas infrastructure such as interstate pipelines, resulting in a certification process that fails to serve the public interest. As FERC begins to re-examine its approval process for new natural gas infrastructure, our report analyzes the Commission’s authority to consider a broader range of factors when deciding whether a proposed project is in the public interest. The report offers four key recommendations for reform.

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  • Assessing the Costs and Benefits of Mandatory Climate Risk Disclosure Cover

    Assessing the Costs and Benefits of Mandatory Climate Risk Disclosure

    Climate impacts are already threatening major economic sectors in novel ways and could cost the global economy trillions of dollars annually by 2100. Yet despite their serious implications, climate-related financial risks are under-disclosed by companies and are rarely reported in a way that is useful for investors.

    As the Securities and Exchange Commission (SEC) prepares a new climate risk disclosure rule, this report analyzes relevant case law and highlights best practices that the SEC can follow in estimating the rule’s economic impacts. With trade groups expected to challenge any new disclosure requirement by claiming that its costs exceed its benefits, defending the rule’s economic analysis will be crucial in court.

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  • Costs, Confusion, and Climate Change Cover

    Costs, Confusion, and Climate Change

    Yale Journal on Regulation, Forthcoming

    Recently, some prominent public policy experts and scholars have proposed that a “marginal abatement cost” (MAC) could be used as an alternative to the social cost of carbon (SCC). This article provides conceptual clarity about these metrics, focusing on how a MAC-based threshold could sensibly be used in climate policy, and explaining why it is not a substitute for the SCC.

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  • Transmission Siting Reforms in the Infrastructure Investment and Jobs Act of 2021 Cover

    Transmission Siting Reforms in the Infrastructure Investment and Jobs Act of 2021

    This policy brief highlights Infrastructure Investment and Jobs Act (IIJA) provisions that are relevant to transmission siting, summarizes the changes they effectuate, and describes important implications of those changes for efforts to develop more interstate transmission capacity. It then offers a brief assessment of the IIJA’s overarching significance to such efforts, including by comparing them to a more ambitious legislative alternative.

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  • Carbon Trading for New York City’s Building Sector Cover

    Carbon Trading for New York City’s Building Sector

    Report of the Local Law 97 Carbon Trading Study Group to the New York City Mayor’s Office of Climate & Sustainability

    NYU researchers assessed whether New York City should adopt a carbon trading program for its buildings pursuant to its landmark climate law, Local Law 97 of 2019. The study offered two proposals for trading programs, both of which would benefit the City as a whole, and environmental justice communities in particular, and found that both proposals would lead to deeper GHG reductions and lower the cost of complying with LL97.

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  • Valuing the Future: Legal and Economic Considerations for Updating Discount Rates Cover

    Valuing the Future: Legal and Economic Considerations for Updating Discount Rates

    Yale Journal on Regulation, Forthcoming

    This article explores the legal and economic considerations for updating discount rates and details the compelling economic evidence for lowering the current default rates for regulatory analyses. It argues that a declining discount rate framework can consistently harmonize agency practices and so put agencies on sound legal footing in their approach to valuing the future.

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  • Poisoning America Cover

    Poisoning America

    A “Reasoned Consistency” Response to the Trump Administration’s Regulatory Shell Game

    Published in the NYU Environmental Law Journal, the article analyzes the inconsistent manner in which the Trump administration dealt with cost-benefit analysis, federalism, and the treatment of dirty, old sources of pollution in the design of environmental policy. The article finds that though inconsistencies across different regulations— as opposed to inconsistencies within a single regulation—have not been a core concern of the Administrative Procedure Act, its prohibition on “arbitrary and capricious” agency action is sufficiently capacious to embrace egregious inconsistencies.

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  • Regulating New Fossil-Fuel Appliances Under Section 111(b) of the Clean Air Act Cover

    Regulating New Fossil-Fuel Appliances Under Section 111(b) of the Clean Air Act

    This report finds that EPA has authority under Section 111(b) of the Clean Air Act to set nationwide performance standards for new residential and commercial fossil-fuel appliances and that multiple means of reducing emissions from such appliances are adequately demonstrated, including the use of electric-heat-pump technology.

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