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Carbon Trading for New York City’s Building Sector
Report of the Local Law 97 Carbon Trading Study Group to the New York City Mayor’s Office of Climate & Sustainability
NYU researchers assessed whether New York City should adopt a carbon trading program for its buildings pursuant to its landmark climate law, Local Law 97 of 2019. The study offered two proposals for trading programs, both of which would benefit the City as a whole, and environmental justice communities in particular, and found that both proposals would lead to deeper GHG reductions and lower the cost of complying with LL97.
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Comments on EPA’s Draft 2022–2026 Strategic Plan
The comments encourage EPA to clearly articulate in its final strategic plan that the agency will incorporate environmental justice and equity into its rulemakings and regulatory impact analyses and recommends several steps toward that end. These include: analyzing the distributional consequences of regulatory alternatives; developing a standard approach to distributional analysis that accounts for the methodological considerations described in the comments; and conducting a distributional analysis of at least one economically significant regulation within the next year incorporating our recommendations.
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Joint Comments on Federal Agency Climate Adaptation and Resilience Plans
Policy Integrity joined other members of the Initiative on Climate Risk and Resilience Law to file comments on the Federal Climate Adaptation Plans recently issued as part of the Biden Administration's Whole-of-Government approach to climate change. Our comments recognize the importance of those plans' issuance and recommend further steps to ensure that federal agencies' approaches to adaptation reflect rigor, transparency, and coherence with respect to other climate-related objectives.
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Comments to NRC on Addressing Environmental Justice
Policy Integrity’s comments advise the NRC to look to FERC's efforts to improve stakeholder engagement and consideration of environmental justice impacts and iterate our recommendations in the related proceedings. We highlight the benefits from robust public participation, share best practices for stakeholder engagement, and recommend ways the Commission can improve its environmental justice analysis and incorporate the findings of that analysis into its review process under the National Environmental Policy Act.
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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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Comments to NHTSA on Proposed Car Standards
We submitted comments on NHTSA's proposed car standards, recommending ways that the agency could improve its modeling and address inconsistences between its and EPA's analyses. We also submitted joint comments on NHTSA's use of the social cost of carbon, recommending that the agency expand its justification of its discount rates and inclusion of global damages in the SCC.
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Comments to DOE on Manufactured Housing Energy Conservation Standards
Policy Integrity submitted joint comments to the Department of Energy’s Supplemental Notice of Proposed Rulemaking for its Manufactured Housing Energy Conservation Standards. Our comments recommend that DOE provide additional rationale for applying the Working Group’s numbers, including by explaining why it is appropriate to focus on a global perspective of climate damages and exclude a 7% discount rate from its analysis of these damages.
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Comments to Colorado PUC on Joining an RTO
Policy Integrity signed on to comments filed with the Colorado Public Utilities Commission (PUC) by Western Resource Advocates and the Western Grid Group. These comments sum up the key arguments presented in the long-running docket in which the PUC has considered questions about participation in a competitive wholesale market. The comments organize the points made in support of Colorado opting to join a new western Regional Transmission Organization (likely an expanded version of California's ISO+EIM) instead of joining SPP to the east or establishing its own Colorado-only RTO.
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Comments to US Postal Service on Delivery Vehicle Acquisitions
The U.S. Postal Service committed to acquiring at least 10% battery electric vehicles (BEVs) over the next decade. We filed comments supporting that decision for monetizing the social cost of the project's marginal greenhouse gas emissions and describing several ways the Postal Service should extend its analysis.
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Regulating New Fossil-Fuel Appliances Under Section 111(b) of the Clean Air Act
This report finds that EPA has authority under Section 111(b) of the Clean Air Act to set nationwide performance standards for new residential and commercial fossil-fuel appliances and that multiple means of reducing emissions from such appliances are adequately demonstrated, including the use of electric-heat-pump technology.