Document Type

Article

Publication Title

Texas Journal of Oil, Gas, and Energy Law

Abstract

The Supreme Court, for the first time, elevated economic calculation to function as the fulcrum leveraging and allocating law-making power between the branches of government.

The federal agency regulation before the Supreme Court was estimated by the agency to impose approximately $9.6 billion in costs annually on the U.S. economy, to realize direct public benefits of $4-5 million annually. This is approximately a 2,000:1 negative cost/direct benefit ratio, before counting indirect ‘co-benefits.’ There is now new pressure to “change the math” by which the agency performs the now-required cost consideration. Incidental ‘co-benefits,’ if allowed to be considered, change the result.

This closely divided Supreme Court decision changes Chevron deference previously routinely afforded pursuant to this most-cited administrative decision in U.S. history. Every aspect of this new regulatory frontier is a matter of first impression for the Court.

First Page

119

Last Page

177

Publication Date

2018

Creative Commons License

Creative Commons Attribution-NonCommercial 4.0 International License
This work is licensed under a Creative Commons Attribution-NonCommercial 4.0 International License

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