Tom Ewing’s Regulatory Update

Just the facts, Ma’am…: The Office of Management and Budget (OMB) announced availability of an updated ‘‘Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990.’’ The 48-page document is open for comments until June 21. The broader notion here is a social cost of greenhouse gases and this is hardly just think-tank pointy-headed policy wonk stuff. However these cost numbers play out they will lace through and pivot every upcoming energy policy decision for the next 32,000 years. A “social cost” is fundamental to justify the ongoing pricing policies needed to support renewable energy, to continue support for RECs, tax subsidies, utility riders, ratemaking and state tax policies. Fortunes will be made depending on policy-makers’ decisions about this number.

* Timelines may increase…: The mighty federal government, via change-agent FERC, stepped up and made the tough call to help with a temporary parking lot at a pipeline project in Bechtelsville, PA. The project sponsor needed temporary space for employee parking. After getting a “yes” from the landowner, project managers submitted a variance to FERC and within five days FERC said “ok,” you may use that 0.13 acre parcel, “currently planted in a cover crop of grass,” for parking. That’s just five daysand the request for this ATWS (“additional temporary workspace”) variance required only 18 pages! Pretty soon, though, that will seem like the good ol’ days. Wait until an ATWS variance for 0.13 acres has to be evaluated for climate impacts, resiliency, impacts to disadvantaged communities particularly communities of color, the social cost of greenhouse gases and sea level rise. Whaddya think? That application might go up to 1800 pages – but no reason it still wouldn’t be a quick review. If necessary, FERC would pay for the #94 bus out of Philly to Wyomissing and then it’s just a short bike ride to Bechtelsville.

*Different times / different headlines: The Fish & Wildlife Service (FWS) announced that an updated “collision risk model” (CRM) is available for review. If you’re a bald or golden eagle, I know you’ve got an eagle-eye on this because the CRM is used to calculate fatality estimates for “take permits” (take, in this usage, is a polite word for killing or maiming) granted to projects with environmental/wildlife impacts. The take estimates are used to get some sense of what’s happening, and what will happen, to, in this case, eagle populations near wind energy projects. If you’re a golden eagle, well, you can breathe a little easier because FWS still views your status as rather iffy and so the allowable takes for your team remain lower. If you’re a bald eagle, though, well, sorry aboutcha buddy, but you guys are judged to be doing well enough to be declared a bit more expendable. (No, I don’t know how that fits into the social cost of carbon…). Imagine the headlines if this decision was made six months ago: “Trump Says ‘Throw Bald Eagles Under the Bus!’” These days, in contrast, FWS’ announcement, all tied up in a bow with polite and statistically-proper big words, didn’t even make it to the last page in Actuarial Adventures, not even the paper edition.

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