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Environmental Justice: The Evolution Of A New Federal Regulatory Program - Clean Air / Pollution

An Updated Look at Civil Liability and Litigation Risks Associated with Climate Change | Pillsbury Winthrop Shaw Pittman LLP

Letter Opposing Use of Social Cost Analysis in Certification of Natural Gas Developments - Energy Industry Today

Letter Opposing Use of “Social Cost” Analysis in Certification of Natural Gas Developments The Commission has previously and correctly recognized that this is a fatally-flawed concept when it refused “to use ‘social cost of carbon’ analysis or a similar analytical tool to analyze the environmental impacts of greenhouse gas emissions from the construction and operation of the converted [natural gas] facilities.” EarthReports, Inc. v. Fed. Energy Regul. Comm’n, 828 F.3d 949, 956 (D.C. Cir. 2016). The Commission did so because it concluded that the SCC would not be “appropriate or informative” due to three factors: “the lack of consensus on the appropriate discount rate leads to significant variation in output,” the SCC “tool does not measure the actual incremental impacts of a project on the environment,” and “there are no established criteria identifying the monetized values that are to be considered significant for NEPA purposes.” Id. (internal quotatio

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