CPR Archive for Emily Hammond

Trump's Executive Order on Climate Policy Rollbacks, Annotated

by Emily Hammond | March 29, 2017

Donald Trump's anti-climate action executive order is, as CPR President Rob Verchick puts it, a classic act of bullying. As I describe in an annotated version of the order, it is also irrational, failing to achieve the very aims it purports to support while inflicting damage to our climate, environment, natural resources, wildlife, and yes – even our coal miners. 

In the annotation, I walk through each section of the order, providing an analysis and commentary on just what it does and doesn't do. At bottom, it steps us back to the dark ages of energy and environmental policy. As the agencies struggle to implement the new policies against a record of scientific consensus and ever-growing examples of the costs of climate change, the role of citizens and watchdog groups will become increasingly important. It's time to roll up our sleeves, dig into the administrative process, and do everything we can to keep Trump's policies from ...

The Importance of the Murray Energy Case and Administrative Procedure

by Emily Hammond | April 21, 2015
Last week, the D.C. Circuit heard oral argument on a highly unusual attempt to short-circuit EPA’s rulemaking process for greenhouse gas regulation of existing power plants.  Despite statutory and constitutional hurdles to premature litigation, the petitioners—the coal-fired industry and coal-producing states—argued that the importance of the proposed rule justifies court intervention. The rule’s importance is precisely why it is critical that the agency complete the administrative process. That industry groups will file lawsuits over EPA’s greenhouse gas initiatives is unremarkable.  ...

Power Plant Regulation and the Rhetoric of Reliability

by Emily Hammond | March 15, 2013
The coal-fired power plant industry has always fought air-emissions standards enacted pursuant to the Clean Air Act (CAA).  But the industry has increasingly raised the specter of reliability problems, arguing that EPA’s recent “tsunami” of regulations will cause a “train wreck,” forcing companies to retire aging plants so rapidly that lost capacity will outpace the development of new sources.  The result, they maintain, will be such an unmanageable strain on the regional grids that they will have to impose brownouts ...

Keeping the Independent Agencies Independent

by Emily Hammond | September 13, 2012
The proposed Independent Agency Regulatory Analysis Act, S. 3468, is a troubling idea. As Rena Steinzor explained here when the bill was introduced, it would authorize the President to bring independent agencies under the purview of OIRA.  This proposal is worrisome given the persistent flaws inherent in OIRA’s cost-benefit approach; extending the reach of a poorly functioning process is hard to justify.  But even more problematic is where S. 3468 treads:  the domain of independent agencies.  This development calls for ...

Also from Emily Hammond

 Emily Hammond is a Professor of Law at the George Washington University Law School.

Power Plant Regulation and the Rhetoric of Reliability

Hammond | Mar 15, 2013 | Environmental Policy

Keeping the Independent Agencies Independent

Hammond | Sep 13, 2012 | Regulatory Policy

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