This Administration specializes in arguments for ignoring the evidence.
The Trump Administration’s major deregulatory efforts share a common theme. They assiduously avoid having to rely on scientific or economic evidence. Confronting that evidence is time-consuming and difficult, particularly when it often comes out the other way. Instead, the Administration has come up with clever strategies to shut out the evidence. The effort to repeal …CONTINUE READING
The Trump EPA has come up with a way to hide hundreds of deaths in plain view.
According to press reports, EPA is preparing to ignore possible deaths caused by concentrations of pollutants occurring below the national ambient air quality standards (NAAQS). This is a key issue in a lot of decisions about pollution reduction. For instance, there is no NAAQS for mercury, but pollution controls on mercury would, as a side …CONTINUE READING
The Trump Administration cares about regulatory costs. Regulatory benefits? Not so much.
Since Ronald Reagan’s time, there has been a consensus among conservatives that cost-benefit analysis (CBA) should be the gold standard for regulation. That approach has given them common ground with moderates such as Cass Sunstein, many economists (whether liberal or conservative), and at least a few scholars more environmentally inclined. Cost-benefit analysis has had its …CONTINUE READING
Ignoring co-benefits violates well-established legal principles.
The Trump Administration is moving toward the view, long popular in industry, that when it regulates a pollutant, EPA can consider only the health impacts of that particular pollutant – even when the regulation will also reduce other harmful pollutants. This idea is especially important in climate change regulation, because cutting carbon emissions almost always …CONTINUE READING
Incorporate Elements of SB 775 and AB 378 to Build on a Proven Program
California is in the process of defining the next chapter of its world-renowned climate leadership. Having pioneered a set of policies over the past decade that have put the state on course to meet its greenhouse gas emissions limit in 2020, lawmakers now face the question of what role the state’s cap-and-trade program should play …CONTINUE READING