Federal Climate Policy
Exploring Potential Challenges to EPA’s New Source Performance Standard: PART III
CCS for coal power plants, but not natural-gas power plants?
This post is the third in a mini-series (see first and second posts) exploring likely legal challenges to the New Source Performance Standard (NSPS) for power-plant greenhouse gas emissions under Clean Air Act § 111(b), and how those challenges might affect the Clean Power Plan. In my first post on EPA’s New Source Performance Standard …
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CONTINUE READINGIs CCS the “best” system of emission reduction for coal-fired power plants?
Exploring Potential Challenges to EPA’s New Source Performance Standard: PART II
This post is the second in a mini-series (see first post) exploring likely legal challenges to the New Source Performance Standard (NSPS) for power-plant greenhouse gas emissions under Clean Air Act § 111(b), and how those challenges might affect the Clean Power Plan. In my first post on EPA’s New Source Performance Standard (NSPS) for …
Continue reading “Is CCS the “best” system of emission reduction for coal-fired power plants?”
CONTINUE READINGIs Carbon Capture & Sequestration (CCS) the Biggest Threat to the Clean Power Plan?
Exploring potential challenges to EPA’s New Source Performance Standard: PART I
This post is the first in a mini-series exploring likely legal challenges to EPA’s New Source Performance Standard (NSPS) for power-plant greenhouse gas emissions under Clean Air Act § 111(b), and how those challenges might affect the Clean Power Plan. I will leave detailed exploration of the Clean Power Plan for later posts, but suffice …
CONTINUE READINGCalifornia’s Effort To Set 2030 Greenhouse Gas Emissions Fails
What are the implications for ongoing climate efforts?
In another, even bigger setback for the environmental community in California, SB 32 (Pavley), the bill to set greenhouse gas targets for 2030 and 2050, was pulled yesterday and will be tried again next year. The winners are the oil companies, who face tough regulations and competition from California’s climate efforts. The failure is a …
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CONTINUE READINGThe Shadow Price of Carbon
Merging Cost-Benefit Analysis and Feasibility Analysis
The U.S. government has devoted a lot of time and effort to estimating the social cost of carbon. This is basically a standard exercise in cost-benefit analysis, following a familiar three-step process: 1. Impacts. Figure out the physical impacts of the emissions. This involves setting up some emissions scenarios and then running computer simulations to …
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CONTINUE READINGThe Top Ten Reasons Trump Should Endorse a Carbon Tax
A bold move, if Trump is brave enough to go there.
Not that he’s asked for my advice, but here are ten powerful reasons why Donald Trump should endorse a carbon tax: 10. It would be completely inconsistent with his past positions. 9. It would shock the GOP establishment. 8. It would shock the media. 7. He’s already endorsed a tax increase for …
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CONTINUE READINGGuess Who Benefits From Regulating Power Plants
The answer will surprise you.
What parts of the country benefit most from the series of new EPA rules addressing pollution from coal-fired power plants? The answer is not what you think. EPA does a thorough cost-benefit analysis of its regulations but the costs and benefits are aggregated at the national level. In a new paper, David Spence and David Adelman from the University …
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CONTINUE READINGDueling Laws and the Clean Power Plan
EPA has shifted its position toward more readily defensible ground.
One of the most serious legal challenges to EPA’s Clean Power Plan — and probably the only one that could completely derail it — involves an exceptionally abstruse legal issue. When Congress tried to amend an obscure part of the Clean Air Act, someone screwed and two different versions were included in the final law. That …
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CONTINUE READINGCoal States File Premature Petition to Block Clean Power Plan
AGs Sue For Tactical and Political Reasons Even Though Their Legal Case is a Loser
Attorneys General from 15 states, led by West Virginia, filed a petition in federal court yesterday to block the Clean Power Plan (CPP) from going into effect. The filing seems to be more tactical and political than a serious legal claim: the Environmental Protection Agency has yet to publish the rule in the Federal Register …
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CONTINUE READINGPolitics v. Legality and the Clean Power Plan
EPA’s Final Plan Changes State Targets, With New Winners and Losers
When the President released the final version of the Clean Power Plan last week, it contained a number of big alterations to the draft plan. One of the most significant changes was the way each state’s greenhouse gas emissions target was calculated. The bottom line is that — generally — states more heavily reliant on …
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