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Distributional Consequences and Regulatory Analysis
Published in Environmental Law
This article examines what it would take for the Biden effort at incorporating environmental justice into regulatory decisionmaking to succeed where the Clinton and Obama efforts failed. It argues that agencies will need to be provided with clear guidance on the methodologies used to conduct distributional analysis, and that the lack of a standardized approach is part of the reason prior efforts failed. It further argues that agencies will need to take seriously the already existing requirement of analyzing the distributional consequences of different regulatory alternatives. Otherwise, they will never be in a position to answer the key question in this area: when are the better distributional consequences of one alternative sufficient to overcome another alternative’s higher net benefits?
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Comments on Interior’s Review of Oil and Gas Program
The Department of the Interior is conducting a review of its federal oil and gas leasing program. We submitted comments encouraging the Interior to pursue concurrent action on three fronts.
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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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Comments to USPS on Purchase of Delivery Vehicles
The United States Postal Service (USPS) announced that it will prepare an environmental impact statement for the purchase of a mix of gas-powered and electrict delivery vehicles. We submitted comments on how the USPS can incorporate climate impacts into its review by using the social cost of greenhouse gases. We also urge the USPS to consider the alternative of an all zero-emission fleet.
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Gauging Economic Consensus on Climate Change – Issue Brief
We conducted a large-sample global survey on climate economics, which we sent to all economists who have published climate-related research in the field’s highest-ranked academic journals; 738 responded. To our knowledge, this is the largest-ever expert survey on the economics of climate change. The results show an overwhelming consensus that the costs of inaction on climate change are higher than the costs of action, and that immediate, aggressive emissions reductions are economically desirable.
This Issue Brief highlights key takeaways from the survey. A more detailed report is available here.
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Gauging Economic Consensus on Climate Change
We conducted a large-sample global survey on climate economics, which we sent to all economists who have published climate-related research in the field’s highest-ranked academic journals; 738 responded. To our knowledge, this is the largest-ever expert survey on the economics of climate change. The results show an overwhelming consensus that the costs of inaction on climate change are higher than the costs of action, and that immediate, aggressive emissions reductions are economically desirable.
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Policy Shifts in a Pandemic
Assessing the Environmental Laws and Policies Weakened in Response to Covid-19
The Covid-19 pandemic has led federal, state, and municipal policymakers to adopt a number of measures that suspended, delayed, or relaxed a variety of environmental safeguards. Our report analyzes these pandemic-related policy shifts and their impacts on public health and the environment. We also provide guidance on how agencies can increase transparency about these actions, counteract detrimental effects, and preemptively create guidelines to improve responses in a future emergency.
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An Evaluation of the Benefit-Cost Analysis in the 2020 Steam Electric Reconsideration Rule
85 Fed. Reg. 64,650 (Oct. 13, 2020)
In its analysis of the 2020 Steam Electric Reconsideration Rule, the Environmental Protection Agency failed to adequately provide quantitative estimates for numerous harms from steam electric power plants' wastewater streams and drew conclusions about the rule’s impacts that are undermined by a fair assessment of unquantified impacts. Our report identifies flaws in the 2020 Rule and details changes the agency can make to significantly improve its benefit-cost analysis.
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Resource Adequacy in a Decarbonized Future
Wholesale Market Design Options and Considerations
This report examines the relationship between resource adequacy and renewable energy. It explores the impacts of renewables on the functioning of resource adequacy mechanisms and how different resource adequacy approaches affect renewable investment, finding that current approaches—with certain adjustments—are capable of ensuring that the lights stay on during a future that is powered largely by renewable energy.