-
Coal Reform Publications, Workshop for Policymakers
As the Department of the Interior continues its review of the federal coal leasing program, we recently released two new publications on coal reform and hosted a related workshop for government officials.
-
Next Steps to Reform the Regulations Governing Offshore Oil and Gas Planning and Leasing
Published in the Alaska Law Review
In this article, we argue that fundamental reform is necessary and highlight a series of key themes and topics that must be addressed to improve the regulatory process and promote better, more consistent management outcomes. While the article draws on examples from frontier areas-in particular the U.S. Arctic Ocean-the recommended changes would apply to and benefit all areas of the OCS.
-
Priorities for Federal Coal Reform
Twelve Policy and Procedural Goals for the Programmatic Review
This report highlights twelve policy and procedural recommendations for the review of the federal coal program. These reforms are intended to help modernize program and so that it can provide maximum net benefits to American taxpayers. The programmatic review should identify opportunities to increase revenue, reduce greenhouse gas emissions, and align federal land management with U.S. climate change goals, paying enormous dividends to the public.
-
Comments on Proposed Offshore Leasing Program for 2017-2022
We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values.
-
Legal Pathways to Reducing Greenhouse Gas Emissions Under Section 115 of the Clean Air Act
The most efficient legal tool for addressing U.S. climate pollution can likely be found in an unused provision of the Clean Air Act. Section 115 of the Act, titled “International Air Pollution,” authorizes the EPA to develop and implement an economy-wide, market-based program to reduce domestic greenhouse gas emissions. This article, jointly authored by a team of law professors and attorneys at three of the country’s leading institutes focused on climate change and environmental law, offers an in-depth analysis of Section 115, which would provide the most flexible approach for achieving the targets from the Paris climate agreement.
-
The Bureau of Land Management’s Modeling Choice for the Federal Coal Programmatic Review
There are multiple power sector models available to the Department of Interior (DOI)’s Bureau of Land Management (BLM) for analyzing the effect of current and alternative coal regulations and leasing policies during preparation of its programmatic environmental impact statement (PEIS). This document lays out model selection criteria to assist BLM in weighing the benefits and costs of these available models, and offers recommendations for model selection, highlighting the tradeoff between model complexity and transparency.
-
Revesz Testifies at Senate Hearing on Clean Power Plan
On June 9, Richard Revesz testified at a Senate Environment and Public Works Committee hearing focused on the Supreme Court’s stay of the Clean Power Plan.
-
The Turn Toward Toxins
An Essay Review
A growing number of historians have begun to turn their attention to crucial transitions in the ‘chemical age’ of the 20th century in order to understand both how ‘invisible’ chemicals endangered the environment and public health as well as how science and technology mediated perceptions of this danger. Several important new works have demonstrated the need for scholarship not only on the environmental and health effects of pollutants, but also on how institutions and governments began to care about such changes and define them positively or negatively.
-
National Academy of Sciences Reviews Social Cost of Carbon
The National Academy of Sciences (NAS) is currently conducting a review of the methodologies used to calculate the Social Cost of Carbon (SCC). We submitted comments to NAS to help inform this process.
-
Distributed Energy Compensation Comments for NARUC
As distributed energy resources (“DER”) are becoming increasingly common, the debate on how customers with such systems should be compensated is intensifying in many states. The National Association of Regulatory Utility Commissioners (NARUC) is creating a Distributed Energy Resources Compensation Manual to assist states with these policy decisions. We recently submitted comments to NARUC’s Staff Subcommittee on Rate Design regarding the most economically desirable approach to use for DER compensation.