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Supreme Court Amicus Brief on EPA’s PSD Permitting Case
Policy Integrity filed an amicus brief with the U.S. Supreme Court supporting the authority of the Environmental Protection Agency (EPA) to regulate greenhouse gas emissions from stationary sources under the prevention of significant deterioration (PSD) program.
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Comments on EPA Proposed 2014 Standards for the Renewable Fuel Standard Program
Policy Integrity submitted comments to the Environmental Protection Agency (EPA) on the agency’s proposed 2014 standards for the Renewable Fuel Standard (RFS) program. EPA proposes to reduce renewable fuel targets from 2013 levels, due to concerns regarding industry’s ability to produce sufficient quantities of qualifying fuel and consumers’ ability to use the fuel. This backsliding highlights the RFS program’s inability to guarantee steady reductions in greenhouse gas emissions.
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Comments on Con Edison Storm Hardening and Resilience Collaborative Report
On January 10, Policy Integrity, along with New York University’s Guarini Center, submitted comments on Con Edison’s Storm Hardening and Resilience Collaborative Report. The comments urge New York’s Public Service Commission (PSC) to extend the charter of the cost-benefit analysis working group convened as part of the collaborative process surrounding Con Edison’s latest ratemaking proceeding.
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Quantifying Regulatory Benefits
The author responds to an argument made by Cass Sunstein that administrative agencies should use breakeven analysis when unable to quantify benefits of a specific regulation. Breakeven analysis seeks to determine how high nonquantifiable benefits of a regulation would have to be for the benefits to justify the costs. In this Comment, the author argues that breakeven analysis can be useful but is always a second-best technique. The first-best approach is to quantify the benefit.
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Cost-Benefit Analysis and Agency Independence
In “Cost-Benefit Analysis and Agency Independence,” Professor Michael A. Livermore argues that cost-benefit analysis provides a standard that constrains the exercise of OIRA’s power, helping to preserve the autonomy of government agencies in the face of White House review. This argument challenges the prevailing view that cost-benefit analysis is a tool for the President to impose authority over executive agencies.
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Burning Rain: The Long-Range Transboundary Air Pollution Project
Book Chapter
This chapter, in Toxic Airs: Body, Place, Planet in Historical Perspective, assesses the development of the first international study to examine the atmospheric transport of pollutants that cause acid precipitation: the long-range transboundary air pollution project.
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Court of Appeals for DC Circuit Hears Oral Arguments on Mercury and Toxic Standards
The U.S. Court of Appeals for the D.C. Circuit heard challenges from industry, conservative states and some environmental groups to the Environmental Protection Agency’s (EPA) Mercury and Toxic Standards (MATS) rule for coal- and oil-burning power plants.
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Policy Integrity Staff Attend Supreme Court Oral Arguments on CSAPR
Policy Integrity director, Richard Revesz, legal director, Jason Schwartz, and legal fellow Denise Grab were at the Supreme Court today to hear oral arguments in the case against EPA’s Cross-State Air Pollution regulation. This challenge to EPA’s rule reaches the nation’s highest court after the U.S. Court of Appeals for the D.C. Circuit decided against EPA. That decision set aside three decades-worth of consistent agency interpretation of the Clean Air Act by six administrations of both political parties, to disallow EPA from taking into account the costs of pollution reductions and using market mechanisms to allocate the pollution control burden between upwind and downwind states.
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ACUS Accepts Policy Integrity’s Recommendation on Remand Without Vacatur
The Administrative Conference of the United States (ACUS) Committee on Judicial Review accepted a recommendation made by Policy Integrity on remand without vacatur.
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Water Pollution and Regulatory Cooperation In China
The costs of China’s record economic growth—including pollution—threaten to undercut its progress if left unchecked. Standing in the way of China’s efforts to control pollution is a complex political system of overlapping levels of local and national authorities. This paper examines recent efforts to address the ill-aligned incentives lead some officials to allow high levels of pollution.