Excerpt: These controversial estimates are currently being used by federal agencies to place dollar values on the potential climate damages purportedly avoided by carbon dioxide reduction in regulatory actions, with measurements of such effects extending hundreds of years into the future. The implications of quantifying future impacts raises serious questions about how federal agencies are developing these estimates to advance rulemaking.
Letters to Federal Agencies Regarding Development and Use of Estimates for the Social Cost of CarbonSeptember 26, 2013 | Letter
Excerpt: We support the Commission's timely examination of the important issues surrounding centralized capacity markets, and today, we write to encourage the Commission to also consider the many other critical issues facing RTOs and ISOs, either as part of the capacity market proceeding or a seperate proceeding. To read the letter, click here.
Excerpt: The questions and concerns that emerged from our review appear to be a direct result of the rushed implementation of the Navigator program by HHS and the limited time available for training Navigator grant recipient organizations and their staff… Although you acknowledged that your office is responsible for overseeing the Navigator program, you explained that you had not reviewed the individual grant applications and therefore could not comment on the individual Navigators’ planned e
Excerpt: We urge the commission to ensure that any changes it makes to the UHF discount rule respect the holdings of existing licensees and applications pending at the commission and are only applied prospectively to applications filed after the adoption of a new rule. To read the letter. click here.
Advanced Medical Technology Association Association of Global Automakers, Inc.
Excerpt: While it is our understanding that CMS has made some progress in implementing the SMART Act and improvements to the MSP program, some challenges remain. In August 2011, CMS announced that it would only pursue those claims with a recovery value of $300 or more in certain liability insurance cases. However, it is our understanding that CMS continues to pursue claims below the $300 threshold.