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Issue Briefs
A Lower Bound
The Social Cost of Carbon, developed by the Obama-era Interagency Working Group (IWG), is the best available tool for measuring the economic damages from greenhouse gas emissions. It has been used in analysis for over 100 federal regulations that affect greenhouse gas emissions, as well as by a number of states in electricity and climate policy. Still, many significant impacts identified by the Intergovernmental Panel on Climate Change are difficult to quantify and so have been omitted from the IWG SCC estimates. Impacts such as increased fire risk, slower economic growth, and large-scale migration are all unaccounted for, despite their potential to cause large economic losses. Our new issue brief discusses these omissions and other variables that will influence climate outcomes. We encourage policymakers to account for this likely underestimate by viewing the SCC as a lower bound for damages.
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Public Comments
Comments to BLM on Resource Management in the Powder River Basin
The Bureau of Land Management (BLM) is considering amending Resource Management Plans for the Miles City and Buffalo field offices in the Powder River Basin. The agency will prepare an environmental impact statement (EIS) for the proposal. We submitted comments at the scoping phase urging BLM to provide analysis that quantifies the external costs of fossil fuel development in the region and evaluates critical land management alternatives.
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Public Comments
Comments to BLM on Foidel Creek Mine Expansion
A proposed expansion of the Foidel Creek Mine in Colorado would allow Peabody Energy to recover nearly five million additional tons of federal coal, extending the mine’s life by an additional two years. We submitted joint comments that critique the Bureau of Land Management’s (BLM) environmental assessment of the expansion, which miscalculates downstream emissions and fails to monetize the climate damages those emissions will produce.
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News
Roundup of Trump-Era Deregulation in the Courts
The Trump administration has undertaken numerous deregulatory actions through rule suspensions; repeals; rescissions; efforts to weaken regulations through guidance, memoranda, amendments, or replacements; and more. Many of these actions have been challenged in court and decisions have been reached in several cases.
The Institute for Policy Integrity maintains a publicly available list of those decisions. This “Roundup,” which we update regularly, has been cited by the New York Times, the Wall Street Journal, and the Brookings Institution.
The Roundup provides an overview of each court decision, with relevant links to the government actions and court rulings. It also tallies the successful and unsuccessful outcomes for the administration for ease of reference. Updates should be submitted to bethany.davisnoll@nyu.edu.
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Public Comments
Comments on Environmental Impact Statement for Changes to Grand Staircase-Escalante Monument
The Bureau of Land Management (BLM) recently released an Environmental Impact Statement (EIS) for the Grand Staircase-Escalante Monument and Kanab-Escalante Planning Area. We submitted comments explaining why the agency should analyze the impacts of each land management alternative using Social Cost of Greenhouse Gases estimates.
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Public Comments
Comments on Environmental Impact Statement for Changes to Bears Ears Monument
The Bureau of Land Management and U.S. Forest Service recently released a Draft Environmental Impact Statement (EIS) on their land management proposal for the Bears Ears National Monument. The EIS does not consider the environmental impacts of shrinking the monument’s boundaries. We submitted comments explaining why the agencies are responsible for providing detailed environmental analysis of their proposal to alter the Bears Ears planning area.
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Reports
Deregulation Run Amok
For the first year and a half of the Trump administration, deregulatory efforts focused on suspending regulations across many agencies. But those suspensions flouted public input requirements, ignored statutory mandates, and failed to fully and honestly address the impact of the delays on the valuable benefits conferred by the original regulations. As a result, many have been struck down in court.
Our report provides a survey of the legality of the Trump administration’s regulatory suspensions. Looking at a number of cases, we discuss the administration’s disregard for notice-and-comment requirements, statutory restrictions, and the reasoned explanation requirement. We also lay out some of the challenges facing advocates, and the strategies by which agencies have evaded review. It is worth reflecting on the era of suspensions as the administration moves into repealing rules. The legal principles that applied to suspensions will also apply to repeals, and the same flaws are already appearing in many of the proposals to repeal regulations.
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Public Comments
Comments on Carlsbad Region Fossil Fuel Leasing
We submitted two sets of comments to the Bureau of Land Management (BLM) in response to their Draft Resource Management Plan (RMP), which focuses on mineral development potential in the Carlsbad region of New Mexico. Our comments recommend that BLM not offer more lands for fossil fuel leasing, but instead consider alternatives with the greatest amount of conservation and wildlife protection. In particular, we focus on shortcomings in the RMP’s analysis and its failure to monetize climate damages.
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Public Comments
Comments on Proposed Clean Power Plan Replacement
EPA recently issued a proposal to replace the Clean Power Plan (CPP) with a far weaker rule that will increase greenhouse gas and soot- and smog-forming emissions from the electric sector. Our comments explain why repealing the CPP is unnecessary, irrational, and harmful.
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Public Comments
Comments on Proposed Weakening of Vehicle Emissions Standards
In August 2018, the Trump administration issued a proposal to dramatically weaken federal emissions standards for cars and light trucks, and to revoke the waiver that allows California to set its own standards. Federal emissions standards have been enormously successful at reducing greenhouse gas pollution and lowering fuel costs for consumers, and we recently submitted five separate sets of comments detailing the flaws with the Trump administration’s proposal.
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