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Recent Projects

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  • News

    Helping California Improve Energy Decisionmaking

    March 14, 2018

    California has long been a trendsetter in clean energy policy, and our input helped inform the state’s approach for evaluating distributed energy resources (DERs), such as rooftop solar installations. The state’s new approach, which will quantify the environmental benefits of DERs, could help influence other policies around the country, boosting the growth of clean energy sources. Our comments to the California Public Utilities Commission were heavily cited in a March 2018 administrative law judge ruling, which, if adopted by the Commission, would require utilities to conduct a societal cost test to determine the cost-effectiveness of DERs.

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  • News

    Presentation at the Association of American Law Schools

    January 5, 2018

    Our Litigation Director, Bethany Davis Noll, and Energy Policy Director, Burcin Unel, recently presented a draft paper on federal carbon pricing in wholesale energy markets at the 2018 Association of American Law Schools Conference. In a panel on legal constraints to implementing clean energy policies, they discussed the legal authority of the federal government, specifically the Federal Energy Regulatory Commission, to price carbon emissions in wholesale energy markets and how this authority interacts with state-level clean energy policy.

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  • Court Filings

    Policy Integrity Brief Cited in Housing Rule Decision

    December 23, 2017

    In a decision ordering the Department of Housing and Urban Development (HUD) to implement a fair housing rule that the Trump administration sought to delay, Chief Judge Beryl A. Howell of the U.S. District Court for the District of Columbia cited Policy Integrity’s amicus brief in the case. The Small Area Fair Market Rent rule, finalized under President Obama, seeks to give low-income families greater access to housing in higher-rent neighborhoods and break up areas of concentrated poverty. Our brief argued that, in suspending the rule’s implementation for two years, HUD violated principles of administrative law by disregarding economic impacts and failing to seek public comment. Judge Howell found that HUD’s decision to delay the rule exceeded the agency’s legal authority and that the reasons it gave for doing so were arbitrary and capricious. She ordered HUD to implement the rule by January 1, 2018.

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  • News

    ACUS Adopts Recommendations on Marketable Permits

    December 14, 2017

    The Administrative Conference of the United States (ACUS), an independent federal agency that recommends improvements to government processes and procedures, recently approved a set of recommendations from Policy Integrity’s Jason Schwartz concerning marketable permits. Marketable permits, in the appropriate context, are a powerful tool for achieving policy objectives more efficiently, by letting market participants buy and sell compliance obligations. But like all markets, permit markets require proper oversight to prevent market manipulation. The new recommendations adopted by ACUS provide agencies with best practices on structuring and overseeing marketable permit programs.

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  • News

    Presentation to New York State Policymakers on Carbon Pricing

    December 11, 2017

    Bethany Davis Noll, our litigation director, and Dr. Jeffrey Shrader, our economics fellow, participated in a Technical Conference on carbon pricing in New York wholesale markets, hosted by the New York State Department of Public Service and the New York Independent System Operator. Davis Noll participated in the roundtable discussion on how best to address any potential leakage, expressed our support for efforts to address the issue, and discussed the legal implications of any such efforts. Shrader participated in the roundtable discussion on revenue allocation, expressed our support for carbon pricing as the most economically efficient and technology neutral way of internalizing climate damages from greenhouse gases, and discussed that there are many ways to use the revenue based on policy priorities as long as the revenue allocation does not undo the incentives carbon pricing creates.

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  • News

    Joint Letter to the House Committee on Natural Resources on the Social Cost of Carbon

    November 30, 2017

    We recently submitted a joint letter, coauthored by several environmental groups, to the House Committee on Natural Resources about the “Transparency and Honesty in Energy Regulations Act of 2017.” This act, H.R. 3117, seeks to direct agencies to ignore or drastically undervalue climate damages, and would seriously hamper future use and development of economically and scientifically sound estimates for the Social Cost of Carbon. This would result in federal government decisionmaking that fails to adequately account for the enormous social and economic consequences of climate change. In the letter, we urge the Committee to reject this and any other attempt to weaken, minimize or eliminate the requirement that agencies take into account the cost of climate change.

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  • News

    Response to a Critique of New York State’s Clean Energy Programs

    September 20, 2017

    A recent report criticizing New York’s Clean Energy Standard (“CES”) incorrectly argues that the CO2-reduction benefits from these programs are non-existent. The report claims that the benefits of reducing CO2 emissions with the CES, which are valued using the Social Cost of Carbon (“SCC”), are “effectively zero.” This conclusion and the preceding assertions are incorrect and inconsistent with basic economics. Our response highlights the flaws of the report and explains that New York’s CES in fact generates significant and crucial environmental benefits.

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  • News

    Court Rules Against Bureau of Land Management’s Inadequate Consideration of Climate Effects

    September 15, 2017

    On September 15, 2017, the U.S. Court of Appeals for the 10th Circuit ruled that the Bureau of Land Management (BLM) violated the National Environmental Policy Act (NEPA) by providing an inadequate analysis of the likely climate impacts from four coal leases. This ruling, as argued in our press release on the case, establishes an important judicial precedent. Agencies cannot make unsupported assumptions about climate effects while still complying with NEPA and the Administrative Procedure Act.

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  • News

    Senate Regulatory Reform Bills

    June 1, 2017

    Several bills that recently won Senate committee approval could have devastating impacts on the efficiency and effectiveness of government. Our new fact sheets describe the dangers of these bills.

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  • Court Filings

    Federal Court Supports Use of Social Cost of Carbon

    August 8, 2016

    On August 8, 2016, the Seventh Circuit handed down its opinion in Zero Zone, Inc. v. United States Department of Energy, upholding the agency’s use of the social cost of carbon (SCC) in its regulatory impact analysis of commercial refrigerator energy efficiency standards. The ruling may have paved the way for a new chapter in economically efficient U.S. climate policies, and our brief for the case was acknowledged in the judges’ opinion.

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