How to Deal with Hornets: The Administrative Procedure Act and the Social Cost of Carbon

Author:Jay G. Stirling
Position:J.D. Candidate, University of Iowa College of Law, 2015; B.A., Brigham Young University, 2006

This Note explores the extent to which the 2013 revision to the social cost of carbon ("SCC")—a figure used in the cost-benefit analysis of federal rules involving carbon dioxide emissions—conforms to the Administrative Procedure Act's ("APA") notice and comment process. This Note analyzes two precedents the 2013 SCC revision process set: (1) an agency will not re-notice a proposed rule when it... (see full summary)

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