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Playing with Fire
Responding to Criticism of the Social Cost of Greenhouse Gases
Federal agencies will need to offer considered and detailed responses to objections raised in the notice-and-comment processes for individual regulations or administrative actions that apply the Working Group’s social cost valuations. Given its expertise, the Working Group should consider providing such responses now, so that agencies can then incorporate them into future actions. This working paper offers a blueprint for those responses.
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About Time
Recalibrating the Discount Rate for the Social Cost of Greenhouse Gases (Working Paper)
In light of recent evidence, a new range of discount rates appropriate for calculating the social cost of greenhouse gases could be conservatively estimated as between 0.5%-2.5%, with a central estimate of 1.5%. Agencies should follow the Interagency Working Group’s guidance on applying new social cost of greenhouse gas estimates based on updated discount rates—and will need to justify their choices, including any departures from prior practices.
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Broadening the Use of the Social Cost of Greenhouse Gases in Federal Policy
Our working paper highlights numerous areas in which the federal government should apply the social cost of greenhouse gases beyond regulatory cost-benefit analysis. It is organized under the framework of “decision-making, budgeting, and procurement” laid out in the President’s executive order, identifying a number of relevant actions—like environmental reviews conducted under NEPA and the assessment of royalty rates for federal land-management. In short, application of the social cost of greenhouse gases would be extremely beneficial for any executive branch decision with significant greenhouse gas implications.
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Strategic Policymaking for Implementing Renewable Portfolio Standards: A Tri-level Optimization Approach
Forthcoming
Appropriately designed renewable support policies can play a leading role in promoting renewable expansions and contribute to low emission goals. Meanwhile, ill-designed policies may distort electricity markets, put power utilities and generation companies on an unlevel playing field and, in turn, cause inefficiencies. This paper, forthcoming in IEEE Transactions on Power Systems, proposes a framework to optimize policymaking for renewable energy sources, while incorporating conflicting interests and objectives of different stakeholders.
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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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