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Comments on Duty Length Regulations for Commercial Vehicle Drivers
The Federal Motor Carrier Safety Administration (FMCSA) is proposing to revise duty length regulations for drivers of commercial motor vehicles. We submitted comments focusing on how FMCSA can improve its analysis of costs and benefits to social welfare and driver health.
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Comments on Colorado’s Use of the Social Cost of Greenhouse Gases
The Colorado Public Utilities Commission (CPUC) proposed rule revisions to a recent clean energy bill, providing more information on how social cost of greenhouse gases (SCGG) estimates will be used. We submitted comments encouraging best practices for SCGG application that will help CPUC monetize climate externalities and weigh the costs and benefits of various decisions.
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Testimony on Retirement of the San Juan Coal-Fired Power Plant
Jason Schwartz and Denise Grab prepared a testimony for the New Mexico Public Regulation Commission regarding a proposal to retire the San Juan Generating Units, a coal-fired power plant in New Mexico. Their testimony details how applying Social Cost of Carbon metrics would allow the Commission to better monetize and contextualize the climate impacts of the proposal. Retiring the San Juan coal units would deliver billions of dollars in benefits to agricultural productivity, property values, and human health.
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Comments to BLM on Utah Oil and Gas Lease Sale
The Bureau of Land Management released its updated environmental assessment for May 2015 and February 2016 lease sales in Utah, in response to a court remand in WildEarth Guardians v. Zinke. We submitted comments asking BLM to monetize the real-world climate impacts of the lease sales using the social cost of greenhouse gases.
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Comments to FDA on Health Warning Labels for Cigarettes
The Food and Drug Administration (FDA) is proposing to place new, more effective health warning labels on cigarette packages and advertisements. We submitted comments supporting the proposal and suggesting ways the agency can strengthen its assessment of the new labels’ costs and benefits.
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Comments to EPA on Coal Combustion Residuals Rule
The Environmental Protection Agency (EPA) recently proposed to significantly weaken requirements for the disposal of coal combustion residuals from coal-fired power plants. We submitted comments focusing on inadequacies in EPA’s assessment of the rule’s costs and benefits.
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Court Upholds New York’s Zero-Emissions Credit Program for Nuclear Power
The Albany County Supreme Court rejected a challenge to New York’s Zero-Emissions Credit (ZEC) program, which pays nuclear power plants for the value of avoided carbon emissions. The legal challenge focused largely on the state’s decision to use the Interagency Working Group’s Social Cost of Carbon (SCC) to value emissions.
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Comments to EPA on Changes to New Source Review
We submitted comments to the Environmental Protection Agency (EPA) regarding changes to its New Source Review (NSR) applicability regulations. Our comments focus on EPA’s failure to perform a cost-benefit analysis for the proposed rule.
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Comments on Alaska LNG Project
The Federal Energy Regulatory Commission's environmental assessment of the Alaska LNG project failed to provide a meaningful analysis of the pipeline project's climate effects. We submitted joint comments encouraging FERC to monetize the social cost of greenhouse gases in its Environmental Impact Statement.
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Court Strikes Down Rule Refusing to Limit Cross-State Air Pollution
The U.S. Court of Appeals for the D.C. Circuit vacated EPA’s Close-Out Rule, which allowed upwind states to continue emitting ground-level ozone pollution that significantly contributes to downwind air quality problems. The agency justified the rule by falling back on its analysis from the Cross-State Update, a prior rule that had provided only a partial remedy to interstate emissions. We filed an amicus brief, which argued that EPA fundamentally misunderstood its job in analyzing and choosing between cost-effective options.