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Publications

The Institute for Policy Integrity produces a variety of publications. Our research reports develop in-depth research on our core issues, while our policy briefs and issue briefs provide focused analysis on more timely or particular topics. Our academic articles and working papers offer original scholarly research and analysis from established experts as well as fresh new voices.

Latest Publications

  • Justifying Redistributive Regulations Cover

    Justifying Redistributive Regulations

    Congress often relies on agencies to fill in the details of its transfer programs with regulations, such as those setting eligibility criteria for healthcare, housing, and nutritional assistance. This Article uses three recent rulemakings to illustrate how conventional cost-benefit analysis tends to obscure rather than illuminate agencies’ (often distributional) reasons for issuing such transfer regulations—generating unnecessary legal risk for the agencies and unnecessary confusion for the public. The Article then explains why recently proposed revisions to White House guidance on cost-benefit analysis—including the introduction of an analytic technique called income-based distributional weighting—will not fully resolve this problem. Finally, the Article recommends a new analytic framework for transfer regulations that recognizes the particular relevance of distributional concerns to their promulgation and the distinct challenges of assessing their net benefits.

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  • US Benefit-Cost Analysis Requires Revision Cover

    US Benefit-Cost Analysis Requires Revision

    Letter in SCIENCE Supporting Proposed Adjustment to Discount Rates in Circular A-4

    A critical input in cost-benefit analysis is the discount rate, which determines how much impacts in the future are weighted relative to impacts in the present. Federal guidance currently calls on U.S. agencies to apply discount rates of 3% and 7%. But these rates, particularly the 7% rate, substantially devalue impacts that accrue to future generations, thus putting a thumb on the scale against policies that provide long-term benefits such as environmental and public-health regulation. In April, the Office of Management and Budget (OMB) proposed a comprehensive update to that guidance document, known as Circular A-4. Among other revisions, the draft would update the default discount rate used in federal regulatory analysis to 1.7%. In a letter published in Science, leading global experts on discount rates and cost-benefit analysis support the proposed revision.

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  • The Impact of West Virginia v. EPA on Challenges to FERC’s Authority Under the Major Questions Doctrine Cover

    The Impact of West Virginia v. EPA on Challenges to FERC’s Authority Under the Major Questions Doctrine

    Published in Energy Bar Association Brief

    The Supreme Court’s recent applications of the major questions doctrine have prompted numerous challenges to pending or proposed regulatory actions, including the Federal Energy Regulatory Commission’s (FERC’s) proposed revisions to Order No. 1000’s regional transmission-planning and cost-allocation rules (Transmission Rulemaking) and updated draft policy statements on certification of new interstate natural gas facilities (Draft Policy Statements). This article addresses the impact of West Virginia v. EPA—the most recent Supreme Court case involving the major questions doctrine—on FERC’s regulatory authority.

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  • Value of Distribution System Information for DER Deployment Cover

    Value of Distribution System Information for DER Deployment

    Integration of Distributed Energy Resources (DERs) in power systems exacerbates the existing information problems between power utilities and regulators. DER policies oblivious to the trilemma of information asymmetry between power utilities, DER aggregators, and regulators result in distorted price signals to DER investors, and socially inefficient DER roll-out. Therefore, in this paper, a game-theoretic approach is proposed for modeling information asymmetry in distribution network information and consumer data between the DER aggregators and the power utilities.

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  • Targeted Regulation for Reducing High-Ozone Events Cover

    Targeted Regulation for Reducing High-Ozone Events

    Working paper

    Nitrogen oxides (NOx) are a precursor to ground-level ozone, a pernicious pollutant that is harmful to human health and ecosystems. Despite decades of regulations and a sharp decline in NOx emissions, episodic high-ozone events prevent many areas from attaining air quality standards. Theoretically, spatially or temporally differentiated emissions prices could be more cost effective at reducing such events than a uniform price. To test this prediction, with data from EPA and NOAA spanning 2001–2019, this working paper uses novel empirical strategies to estimate (1) the link between hourly emissions and high-ozone events and (2) hourly marginal abatement costs. These estimates form the basis for simulations that compare uniform and differentiated emissions pricing. Consistent with economic theory, differentiated pricing is substantially more cost effective at reducing high-ozone events, but this advantage depends on the accuracy of the estimated NOx–ozone relationship.

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