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Recent Projects

Viewing recent projects in Public Comments
  • Comments to PHMSA on Proposed Pipeline Safety Initiatives

    In September 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed a regulation to improve the safety of certain gas pipelines. The standards include a suite of reforms to help prevent incidents like the catastrophic 2018 gas pipeline explosions in Merrimack Valley, Massachusetts. In a comment letter, we explain that, while the Proposed Rule and its accompanying regulatory impact analysis are well grounded in applicable statutes and guidance, PHMSA should take further steps to bolster its analysis.

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  • Comments to BLM on the Coastal Plain Supplemental Environmental Impact Statement

    The 2017 Tax Act directed Bureau of Land Management (BLM) to conduct two sales in the Arctic National Wildlife Refuge (ANWR) area known as Coastal Plain totaling at least 400,000 acres by 2024. BLM released a final environmental impact statement (EIS) in September 2019 considering the over 1.5 million-acre area in the ANWR and held the first lease sale in January 2021. Later in 2021, the agency placed a moratorium on all activities relating to BLM’s Coastal Plain leasing program, announced that the analysis conducted in 2019 was legally deficient, and began to prepare a supplemental environmental impact statement. We filed comments on this new EIS and arged that the presentation of climate costs and benefits in the analysis could be made more complete and balanced. 

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  • Comments to NHTSA on New Corporate Average Fuel Economy Standards

    In August 2023, the National Highway Traffic Safety Administration (NHTSA) proposed a regulation to strengthen corporate average fuel economy standards for passenger cars, light trucks, and heavy-duty pickup trucks and vans. In a comment letter, we explain that while the Proposed Rule and its accompanying regulatory impact analysis offer useful starting points, NHTSA should take further steps to ensure the complete presentation of regulatory benefits and costs and should select a regulatory option that best promotes social welfare, consistent with the agency’s legal obligations. We also submitted joint comments with a coalition of other environmental groups on NHTSA’s use of the social cost of greenhouses gases in the Proposed Rule.

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  • Comments to FERC in Support of Technical Conference on Capacity Accreditation

    Policy Integrity submitted comments to FERC in support of American Clean Power Association’s petition for a technical conference on capacity accreditation. Holding a technical conference would be appropriate because accurate accreditation is becoming increasingly difficult as grids accommodate rapidly changing resource mixes with varying energy and reliability attributes, public policy constraints, and increasing/unprecedented extreme weather events. Moreover, accreditation has become more consequential, as capacity market revenues have grown to a significant share of total market payments. We included several questions that would merit discussion at the technical conference.

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  • Comments to DOE on Coordination of Federal Authorizations for Electric Transmission Facilities

    The Department of Energy (DOE) issued a proposed rule under 16 U.S.C. § 824p(h) to expedite the federal authorization of transmission projects. We commented in support of the proposal, including DOE's proposed requirement that project proponents describe how the transmission project would affect power-system greenhouse gas (GHG) emissions. We recommended that DOE clarify that project proponents must also estimate changes to non-power-system GHG emissions (e.g., upstream emissions of natural gas) and power-system emissions of local air pollutants. We also suggested that DOE provide additional guidance on the meaning of terms like "disadvantaged communities" and "communities with environmental justice concerns." Finally, we argued that DOE should provide an opportunity for public comment at the pre-application stage of the process.

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  • Comments to CEQ on Proposed Revisions to NEPA Implementing Regulations

    In July, the Council on Environmental Quality proposed revisions to the implementing regulations under the National Environmental Policy Act. The Proposed Rule reflects a more holistic approach to informing agency decisions with a robust and balanced analysis of environmental impacts. In our comment letter, we suggested improvements to the proposal that would help ensure robust and balanced treatment of environmental impacts in NEPA reviews.

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  • Comments to NJBPU on the Development of Natural Gas Utility Emission Reduction Plans

    The New Jersey Board of Public Utilities is examining how to reduce greenhouse gas emissions from the state's natural gas sector in line with New Jersey's economy-wide emissions reduction goals. Policy Integrity submitted comments focused on the planning process and solutions needed to responsibly transition away from natural gas usage.

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  • Comments to PJM on the Resource Adequacy Critical Issue Fast Path

    PJM Interconnection, which oversees wholesale electricity market operations for the mid-Atlantic region, is undergoing reforms to improve how the market values and prices generation capacity to ensure reliability. Policy Integrity submitted comments focused on PJM's proposed shift to a seasonal capacity market design and other proposed changes to reliability metrics.

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  • Comments on the Consideration of Climate Benefits in Proposed Rule to Limit Methane Leakage from Gas Pipelines

    In May, the Pipeline and Hazardous Materials Safety Administration released a draft regulation to prevent methane leaks from gas pipelines. The agency monetized the climate benefits of the regulation using the social cost of methane, finding that monetized benefits exceeded monetized costs by at least $340 million per year. In our comment letter, we support the agency for applying the social cost of greenhouse gases to estimate the climate benefits of the proposed rule. We also suggest that PHMSA apply additional analysis to each rule using draft updated climate-damage valuations that the Environmental Protection Agency released in November 2022.

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  • Comments to NYSPSC on Its 2040 Zero-Emissions Electricity Goal

    The New York State Public Service Commission recently issued an order seeking input on how to achieve the state's goal of a zero-emissions electricity system by 2040, as required by the Climate Leadership and Community Protection Act (CLCPA). Policy Integrity submitted comments focused on issues such as the relationship between the Commission’s 2040 zero-emissions goal and other elements of the CLCPA, the need for analytic frameworks that rely on best available science and economics, the circumstances under which hydrogen could qualify as a zero-emissions resource, and tracking benefits to disadvantaged communities.

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