Latest Publications

Share:

Carbon Free Boston — Or How to Save the World in a Few Easy Steps

Boston’s Green Ribbon Commission has just released Carbon Free Boston, which outlines a pathway to a carbon-free city by 2050. It’s a thoughtful and careful report. My immediate reaction was two-fold. Of course we have to do...more

Deadlines For Permit Issuance Are Double-Edged Swords

On January 25, 2019, the D.C. Circuit Court of Appeals ruled that applicants for licenses under the Federal Power Act may not reach private agreements with states to circumvent the FPA requirement that states act on water...more

Americans Are Increasingly Sure About Climate Change: That Appears to Include DOD

Two reports crossed my desk this week that, together, made me wonder if we’re finally nearing the tipping point on climate change belief in the United States. First, Yale and George Mason released Climate Change in the...more

Who Needs a Carbon Tax When We Can Raise the Real Estate Excise Tax?

Governor Baker announced on Friday that, as part of his FY 2020 budget, he would be proposing to increase the real estate excise tax in order to fund the Global Warming Solutions Trust Fund. The Governor stated that, in the...more

EPA’s New Approach to Cost Benefit Analysis: Charles Dickens or Alice in Wonderland?

I’ve only now had the opportunity to catch up with EPA’s proposed reconsideration of its approach to cost-benefit analysis for the Mercury and Air Toxics Standards. I don’t know whether I’ve gone done a rabbit hole or it’s...more

Is RGGI For Transportation About to Happen? All Will Be Revealed in 2019

On Tuesday, December 18, 2018, nine Northeastern and Mid-Atlantic states participating in the Transportation Climate Initiative – notably not yet including New York – announced that they...more

Massachusetts Comprehensive Energy Plan — There’s a Lot to Do.

Last week, the Massachusetts Department of Energy Resources released its Comprehensive Energy Plan. It’s a generally solid piece of work, even if it doesn’t say anything hugely surprising. Its various policy recommendations...more

The WOTUS Rule and the Purpose of the Clean Water Act

A lot of proverbial ink has been spilled regarding the Trump administration’s proposal to amend the definition of “waters of the United States” under the Clean Water Act. The administration has focused on what it views as a...more

“Managed Retreat?” — Once More, Scientists Fail to Consult with Branding Specialists

Two seemingly unrelated adaptation stories caught my eye last week. The first involved efforts by the California Coastal Commission to provide guidance on “Residential Adaptation” to climate change. The primary reason why...more

Coming Soon To a Major City Near You — Building Energy Efficiency Standards

Members of the New York City Council have introduced a proposal to impose mandatory building energy efficiency standards. The standards, which vary by building type and use, would apply to buildings greater than 25,000 square...more

Two Strikes Against the Administration’s WOTUS Suspension Rule

In August, a judge in South Carolina issued a nationwide injunction against the “Suspension Rule,” which delayed the effective date of the 2015 Waters of the United States rule. Now, a judge in Oregon has gone even further....more

The National Climate Assessment Projects Major Economic Impacts. The President Doesn’t Believe It. Must Not Be True.

Last week, the government released the Fourth National Climate Assessment. Not surprisingly, it’s largely consistent with the prior assessments...more

Internalize Externalities. How Difficult Can That Be?

Being a poor country environmental lawyer, I don’t often delve into the academic world. I therefore just recently caught up to the article written last year by my friend Dan Esty. Red Lights to Green Lights: From 20th Century...more

Deja Vu All Over Again — The Trump Administration Refuses to Provide “Good Reasons” For Its Change in Course on Keystone XL

On November 8, 2018, Judge Brian Morris granted summary judgment to plaintiffs on some of their claims challenging the State Department’s new Record of Decision for the Keystone XL project. Whatever our Tweeter-in-chief may...more

The UCS Wants to Preserve Existing Nuclear Plants — You Know that Means the Climate Situation Must Be Dire

The Union of Concerned Scientists just released a report, The Nuclear Power Dilemma. As Ken Kimmell, UCS’s President, said in a blog about the report, it: "calls for proactive policy to preserve nuclear power from existing...more

And Then There Were Three: Why Is Massachusetts Still Refusing to Seek NPDES Delegation?

As readers of this space know, I have been mystified by the opposition in Massachusetts to obtaining delegation of the NPDES Program. In my temperate way, I have called it an embarrassment. I have just learned that Idaho...more

A Mixed Bag For Climate Litigation Plaintiffs

Last week there were two court decisions on cases in which groups of citizens are seeking court orders requiring the government to act on climate change. The biggest news was that the Supreme Court denied the stay requested...more

11/6/2018  /  Citizen Suits , Climate Change , SCOTUS

A Short Rant Concerning Transportation Sector GHG Emissions

The Energy Information Administration today released CO2 emissions numbers through 2016. While I could rant about the 21.4% increase in GHG emissions in Florida since 1990, as compared to the 23.7% decrease in Massachusetts...more

The Rubber Begins to Hit the Road on Adaptation

I gave up some time ago on the idea that focusing on adaption was just a means of weaseling out of necessary measures to mitigate climate change. As the extraordinary becomes commonplace, it’s evident that we’ve ignored the...more

11/1/2018  /  Climate Change , Sustainability

EPA’s Latest Particulate Review Shows Impacts Below the Current NAAQS. How Will Trump Avoid Doing Something About It?

Last week, EPA posted its draft Integrated Science Assessment for Particulate Matter. It’s the foundational document for EPA’s periodic review of its National Ambient Air Quality Standard for PM. The current standard for...more

A Carbon Tax Twofer. A Meat Tax? No, Sir.

It’s probably not news that the immediate prospects for a carbon tax aren’t great. I still think that it’s going to seem impossible until, fairly suddenly, it actually happens. Hope springs eternal....more

A Sliver of Hope for the Government’s Remaining NSR Enforcement Cases?

Earlier this month, the 5th Circuit Court of Appeals granted something of a reprieve to EPA’s New Source Review enforcement initiative. The Court first confirmed what everyone other than EPA and DOJ already knew – that...more

Time For Another Superfund Rant: Still Stupid After All These Years.

It’s been some time since I ranted about Superfund, but that’s not because the statute’s gotten any more reasonable. To the contrary, there’s so much to rant about that it usually just seems too futile to bother. Take Scott...more

No Circuit Split Here: Second Circuit Affirms New York’s ZEC Program

As Carol Holahan discussed, the 7th Circuit last month affirmed the Illinois zero emission credit program. Now the 2nd Circuit has weighed in, agreeing with the 7th Circuit and affirming the similar New York State ZEC...more

Are Discharges to Groundwater Potentially Subject to the Clean Water Act? A Circuit Split Tees It Up.

The Sixth Circuit ruled earlier this week that discharges to groundwater are not subject Clean Water Act jurisdiction. We now have the requisite circuit split, opening the possibility of Supreme Court review. For those who...more

853 Results
 / 
View per page
Page: of 35

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide