Recent Projects

The social cost of greenhouse gases provides the best available method to quantify and monetize incremental climate damages. To date, however, the use of the method for such determinations and processes has been sporadic and fairly limited. Published in the Yale Journal on Regulation, this article evaluates the various legal, economic, and institutional controversies surrounding the social cost of greenhouse gases, and explains why this metric should play a critical role in guiding agency policymaking and decision-making related to climate change.

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.

The report argues that an FTC rule requiring reasonable cancellation practices for all market actors and providing clear and specific guidelines would address the harms of immortal accounts. Such regulation would fall under the FTC’s authority and advance the Commission’s mission to protect consumers and competition by preventing deceptive, unfair, and anticompetitive business practices.

In our article published in Energy Economics, we use economic modeling to analytically show the relationship between generation subsidies and energy and capacity markets. We show that the feared capacity price suppression can happen only under limited circumstances and that in the short-run, the subsidies will tend to increase capacity prices. We also demonstrate that while subsidies cannot produce the first-best outcomes, there exists a range of welfare-enhancing subsidy rates and designs that improve welfare, such that regulators should think of subsidies as one of the tools available for increasing electricity market efficiency.

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.

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.

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.

The Trump Administration construed the major questions doctrine enormously expansively and inconsistently, in ways untethered to the Court’s jurisprudence, turning it into little more than an invitation for courts to strike down regulations the Administration did not favor for policy-based reasons. Under the similarly wrongheaded and even broader arguments made by the Administration’s allies, all greenhouse gas regulations could be suspect on major question grounds. Bringing to light these argument's enormously problematic application of the doctrine is important to foreclose their successful revival in future administrations.

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.

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.