This comment letter responds to a request from the Employee Benefits Security Administration, U.S. Department of Labor, for comments on its proposed rule “Fiduciary Duties Regarding Proxy Voting and Shareholder…
| October 5, 2020
When proponents of a tax increase resort to the age-old argument that it is justified because those prospectively subject to it are paying less than their “fair share,” observers safely…
By Benjamin Zycher | September 16, 2020
Let the hysteria begin. The Trump administration has finalized a reform of the federal rules on emissions of methane, the major component of natural gas, from oil and gas production. The existing rules were implemented by the…
By Benjamin Zycher | August 18, 2020
The Trump administration proposed last month a reform of the regulations implementing the requirements of the National Environmental Policy Act, for decades a source of massive delay and cost increases for federal projects, yielding actual environmental harm because of…
By Benjamin Zycher | August 6, 2020
Opposition to infrastructure investment for the production and transport of conventional energy is de rigueur on the environmentalist left, a stance widely justified as an important bulwark for the protection of…
By Benjamin Zycher | August 6, 2020
In a recent New York Times review of Bjorn Lomborg’s new book, “False Alarm: How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet” (Basic Books,…
By Benjamin Zycher | August 4, 2020
This comment letter responds to a request from the Environmental Protection Agency for comments on its June 11 proposed rule “Increasing Consistency and Transparency in Considering Benefits and Costs in…
By Benjamin Zycher | July 29, 2020
This comment letter responds to a request from the Employee Benefits Security Administration, U.S. Department of Labor, for comments on its June 30 proposed rule “Financial Factors in Selecting Plan…
By Benjamin Zycher | July 21, 2020
Opportunities to spend other people’s money are addicting, an eternal truth that now has emerged in full force in the context of corporate governance. Large, publicly-owned businesses, and public-pension funds managing…
By Benjamin Zycher | July 8, 2020
I betray no secret when I report that the modern litigation drive against the fossil-fuel industry is oriented overwhelmingly toward the age-old money chase rather than a concern with environmental…
By Benjamin Zycher | July 6, 2020
In a recent Statement distributed to the membership of the American Economic Association, the Executive Committee led by AEA President Janet Yellen condemned killings of black people by police, violent racism, and…
| June 23, 2020
The Environmental Protection Agency has published and solicited public comments on its draft rule reforming the benefit/cost analytic methodology applied to new regulations promulgated under the Clean Air Act (CAA). However boring…
By Benjamin Zycher | June 17, 2020
There are no free lunches, an eternal truth that does not bode well for the years-long efforts of public officials in Puerto Rico to avoid the realities attendant upon the…
By Benjamin Zycher | May 18, 2020
While genuflecting to its fiduciary responsibility to “promote long-term value” for those whose assets it is managing, Blackrock—the largest asset manager in the world—has announced in the form of a…
By Benjamin Zycher | May 14, 2020
No — Carbon taxes and green policies harm economic growth and jobs The close relationships between real gross domestic product, employment and energy consumption for both less and more developed…
By Benjamin Zycher | May 6, 2020