Publications

Recently, some prominent public policy experts and scholars have proposed that a “marginal abatement cost” (MAC) could be used as an alternative to the social cost of carbon (SCC). This article provides conceptual clarity about these metrics, focusing on how a MAC-based threshold could sensibly be used in climate policy, and explaining why it is not a substitute for the SCC.

This article explores the legal and economic considerations for updating discount rates and details the compelling economic evidence for lowering the current default rates for regulatory analyses. It argues that a declining discount rate framework can consistently harmonize agency practices and so put agencies on sound legal footing in their approach to valuing the future.

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.

In the absence of legislation, critical long-distance transmission can be developed by applying existing federal legal authorities. A number of important regulatory and commercial measures have been proposed, including streamlining transmission planning, upgrading existing transmission system components, putting transmission lines underground, and using existing rights-of-way from highways and railroads. Even if these solutions are adopted, however, state siting requirements may prove an important obstacle to developing an efficient, national transmission grid. So, this paper examines legal authorities already available to the Department of Energy and the Federal Energy Regulatory Commission to develop the interstate transmission capacity crucial to the energy transition.

To ensure policies are based on accurate predictions of climate impacts, it is critical to understand social-ecological system (SES) feedbacks, including how humans change the climate by reacting to a changing climate. Building on recent scholarly work on the topic, this article describes SES interactions and how they can be incorporated into climate policy tools such as the social cost of carbon. The article then proposes a research agenda for the identification, quantification, and integration of climate-society feedbacks into social-cost integrated assessment models (SC-IAMs).