EPA will soon propose performance standards under Section 111 of the Clean Air Act for greenhouse gas pollution. Many argue that to be effective and efficient, the standards should incorporate compliance flexibility. This repport finds widespread agreement in the academic community that § 111 authorizes the use of many types of flexible approaches.
How Do We Know How Much Clean Air is Worth?
EPA recently released a study evaluating the costs and benefits of amendments to the Clean Air Act between 1990 and 2020 to see what cleaner air means for human health and the economy. Holladay’s analysis of EPA’s numbers shows that they’re based on sound science.
Grandfathering has become a common practice in regulating industries like coal power generation. But it is not clear that phasing out polluting plants is beneficial. The costs of retrofitting existing plants to comply with new standard can be higher than the compliance costs for a new plant. Since the costs of shifting to new technology must be borne at some point, (since granfathering can’t be indefinite) it might be best not to grandfather at all so that society can benefit from lower pollution levels earlier. That’s just one of the arguments examined in this working paper.
Efforts to reduce greenhouse gases and control climate change implicate a wide range of social, moral, economic, and political issues, none of them simple or clear. But when regulators evaluate the desirability of climate change mitigation through cost-benefit analysis, one factor typically determines whether mitigation is justified: the discount rate or the rate at which future benefits are converted to their present value.
This working paper evaluates the four principal justifications for intergenerational discounting, which often are conflated in the literature. It shows that none of these justifications supports the prevalent approach of discounting benefits to future generations at the rate of return in financial markets and, more generally, that discounting cannot substitute for a moral theory setting forth our obligations to future generations.
Lessons From New Jersey’s Administrative Process
There is a dearth of studies about the effects of the proceduralization of the rulemaking process on state regulations. In the Regulatory Weeds of the Garden State focuses on regulations promulgated in New Jersey, both prior to and following major procedural changes enacted in the state in 2001.
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