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  • The Social Cost of Greenhouse Gases: A Guide for State Officials Cover

    The Social Cost of Greenhouse Gases: A Guide for State Officials

    As states step up on climate action, they need a way to weigh climate goals against other policy objectives. The social cost of greenhouse gases (SC-GHG) can help policymakers understand the costs and benefits of climate action and inaction. This new guide for state officials explains why the SC-GHG is a useful policy tool and how it can be applied.

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  • Enhancing Consideration of Time Frames in Cost-Benefit Analysis Cover

    Enhancing Consideration of Time Frames in Cost-Benefit Analysis

    Federal agencies frequently provide no justification for their analytical time frame when analyzing the costs and benefits of a policy. This is true even when there are costs and benefits that clearly occur beyond the time frame chosen by the agency. In so doing, agencies risk overlooking key long-term impacts that may justify more stringent regulation.

    This report argues that the Office of Management and Budget (OMB) should take steps to improve how agencies consider analytical time frames in their cost-benefit analyses.

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  • Comments to CEQ on Carbon Capture, Utilization, and Sequestration Guidance

    The White House Council on Environmental Quality (CEQ) recently released interim guidance on Carbon Capture, Utilization, and Sequestration (CCUS) to assist federal agencies with regulation, permitting, and associated activities. We filed comments urging CEQ to update the guidance document with additional targeted recommendations for agencies on monitoring, reporting and verification (MRV) programs; project prioritization; and other topics.

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  • Comments to HHS on Proposed Repeal of the SUNSET Rule

    We submitted comments to the Department of Health and Human Services (HHS) supporting its proposed repeal of the SUNSET Rule, which retrospectively and prospectively established an "expiration date" for thousands of HHS regulations. We explain why the SUNSET Rule is arbitrary and capricious, echoing our earlier comments, and and propose ways that HHS can strengthen its justification for repealing the rule.

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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

    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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  • Making Regulations Fair Cover

    Making Regulations Fair

    How Cost-Benefit Analysis Can Promote Equity and Advance Environmental Justice

    To achieve the Biden administration’s ambitious commitments to equity and environmental justice, agencies will need guidance on how to assess and weigh the distributional effects of policy options. This report recommends steps that the Office of Management and Budget (OMB) can take to mainstream equity into agencies’ decisionmaking.

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  • Comments on FERC’s Office of Public Participation

    The Federal Regulatory Energy Commission (FERC) solicited comment from interested parties on how the Commission should structure their Office of Public Participation to facilitate public engagement. We submitted comments highlighting the potential benefits of public participation by environmental justice communities and identifying best practices that FERC’s Office of Public Participation (OPP) should adopt.

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  • Comments to ACUS on Periodic Review of Agency Regulation

    The Committee on Regulation of the Administrative Conference of the United States requested input on best practices for agencies in undertaking periodic review of their existing regulations. We submitted comments providing a number of recommendations.

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  • Comments to ACUS on Regulatory Alternatives

    The Committee on Regulation of the Administrative Conference of the United States requested input on how agencies should solicit public input on alternatives to rules under consideration. We submitted comments providing a number of recommendations.

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