Menu
Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in Public Comments
  • Comments to EPA on New Effluent Standards for Meat and Poultry Facilities

    In January 2024, the Environmental Protection Agency (EPA) proposed a regulation under the Clean Water Act that would impose new effluent limitations guidelines and standards for the meat and poultry products point source category. As EPA documents, the proposed standards would help improve health and water quality near these slaughterhouse facilities. It would also carry benefits stemming from better-protected habitats for a variety of wild animals. In our comment letter, we explain that, while the Proposed Rule and its accompanying regulatory impact analysis reasonably explain many of these benefits, EPA should take further steps to ensure the complete presentation of regulatory benefits and costs, along with their distribution, and to present its decisionmaking factors transparently.

    Read more

  • Comments to EPA on Amendments to New Source Performance Standards and Emissions Guidelines for Large Municipal Waste Combustors

    In January, the Environmental Protection Agency (EPA) proposed a rule that would amend new source performance standards and emissions guidelines for large municipal waste combustors. The Proposed Rule marks an important, and overdue, step in reducing harmful pollutants from municipal waste combustion. To ensure that EPA regulates in a manner that maximizes social welfare, without leaving potential net benefits on the table, the Institute for Policy Integrity submitted comments recommending that EPA conduct additional analysis.

    Read more

  • Letter to DOE on Programmatic Review of LNG Export Program

    In January, the White House announced a pause on LNG export approvals for the Department of Energy to update its underlying analyses for authorizations, which underpin its public interest determinations. In particular, the announcement notes that DOE’s economic and environmental analyses are outdated and calls for them to be updated. This letter offers recommendations for updating DOE’s analyses.

    Read more

  • Joint Comments to New York State DEC and NYSERDA on New York Cap-and-Invest Program

    The Institute for Policy Integrity submitted joint comments (along with the Guarini Center on Environmental, Energy and Land Use Law) to the New York State Department of Environmental Conservation (DEC) and the New York State Energy Research and Development Authority (NYSERDA) in response to a request for comment on various recent publications and presentations concerning the future New York Cap-and-Invest Program (NYCI).

    Read more

  • Comments to DOE on Proposed Efficiency Standards for Fans and Blowers

    In January, the Department of Energy proposed to strengthen its energy efficiency standards for fans and blowers, which would save consumers in energy costs and reduce pollution that harms public health and exacerbates climate change. Our comment offered several suggestions to improve the rule and accompanying analysis.

    Read more

  • Comments to NYSERDA on Proposed Cost-Effectiveness Test for Updates to the State Energy Conservation Construction Code

    The Institute for Policy Integrity submitted comments to the New York State Energy Research and Development Authority (NYSERDA) regarding its proposal for a new cost-effectiveness test for updates to the state energy conservation construction code. We recommended changes and clarifications that NYSERDA and the Code Council can make to improve their evaluation criteria. 

    Read more

  • Comments to Treasury on 45V Clean Hydrogen Production Tax Credit

    Policy Integrity commented on the Department of Treasury's proposed regulation to implement the Section 45V tax credit for clean hydrogen production from the Inflation Reduction Act. This tax credit subsidizes the production of hydrogen based on its emissions intensity. Our comments leveraged our expertise on the electric grid to advise Treasury on how to accurately measure the emissions intensity of hydrogen from grid-connected electrolyzers.

    Read more

  • Comments to EPA on Draft Scientific Integrity Policy

    On February 23rd, Policy Integrity submitted comments to EPA on its draft Scientific Integrity Policy. The draft Policy appropriately clarifies that economic analyses are protected by the same integrity policies as other scientific assessments, but it currently cites EPA's 2010 Guidelines for Performing Economic Analyses as the only example of a best-practice document that "should be followed" when assessing benefits, costs, and economic impacts. Several key elements of those 2010 guidelines are out of date, notably the recommendations on discount rates. Our comments offer a simple redline to ensure that other documents that meet the standards for objectivity--like the updated Circular A-4, or the pending ecosystem service guidance--could also fall under the Policy's proposed protections. 

    Read more

  • Comments to NYPSC on CLCPA’s Zero-Emissions Amendments to Public Service Law

    Policy Integrity submitted comments to the New York State Public Service Commission (NYPSC) regarding the section of the Climate Leadership and Community Protection Act (CLCPA) that amends the Public Service Law to add a new section (Section 66-p), which requires, among other things, that, by 2040, “the statewide electrical demand system will be zero emissions.” NYPSC had posed several questions about how it should interpret the requirements for 2040 under the new Public Service Law provision. 

    Read more

  • Comments to CFTC on Voluntary Carbon Credit Derivatives Guidance

    In December 2023, the Commodity Futures Trading Commission (CFTC) proposed guidance that identifies key features of high-integrity voluntary carbon credits (VCCs) for exchanges that list certain VCC derivatives. The Institute for Policy Integrity submitted comments that highlight additional sources of CFTC legal authority over these derivatives and suggest improvements to the proposed guidance’s discussions of additionality, leakage risk, quantification, risk of reversal, and exchanges’ discretion to set stringent standards. Finally, our comments recommend that the CFTC explore whether it has other authority to address issues with VCC integrity and whether to seek additional authority from Congress.

    Read more