Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

  • Public Comments

    Comments to California’s Public Utilities Commission on Energy Planning

    July 11, 2017

    We recently submitted comments to California’s Public Utilities Commission, focused on the economic analysis used in its longer-term energy planning process across utilities. We ask the Commission to exercise caution in coordinating or consolidating this planning with other energy-related proceedings, as different proceedings have different goals and statutory requirements.

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  • Public Comments

    Public Comments on the Review of National Monuments

    July 11, 2017

    We recently submitted comments to the Department of the Interior on their review of certain national monuments established since 1996. The review process was initiated by Executive Order 13792, which directs the Secretary of the Interior to review all national monuments designated or expanded after January 1, 1996, that either include more than 100,000 acres of public lands or for which the Secretary determines inadequate “public outreach and coordination with relevant stakeholders” occurred.

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  • Public Comments

    Comments to the Department of Energy on Regulatory Burden

    July 10, 2017

    Following an Executive Order on reducing federal regulatory burden, the Department of Energy (DOE) is requesting the public’s suggestions for rules to repeal or reform. In our comments to DOE’s request for information, we argue that regulatory review should consider the public benefits of regulation, not just the costs to regulated industries.

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  • Public Comments

    Public Comments on Regulatory Review (HUD, MCSAC, FMC, NOAA, Coast Guard)

    July 7, 2017

    Many federal agencies are requesting the public’s suggestions for rules to repeal or reform, tacitly implying that most regulations stifle economic growth. In comments to several agencies, we argue that regulatory review should consider the public benefits of regulation, not just the costs to regulated industries, and should prioritize review of rules for which actual costs and benefits diverge significantly from predicted costs and benefits.

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  • Public Comments

    Comments on EPA’s Proposal to Issue a Second Stay of the Effluent Rule

    July 6, 2017

    Policy Integrity has filed comments opposing EPA’s proposal to issue a second stay of the compliance deadlines in the Effluent Rule—a rule that regulates toxic metal discharges from power plants. As we explained in our comments to EPA, EPA has no legal authority for the proposed stay. In addition, EPA failed to provide a reasoned explanation for the stay because it ignored the impact that the stay will have on the benefits of the Effluent Rule.

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  • Court Filings

    Challenging EPA’s Effluent Rule Suspension

    June 27, 2017

    EPA has suspended the compliance deadlines in a regulation on power plant wastewater discharges, which limits plants from releasing certain toxic metals into lakes and rivers. We submitted a “friend of the court” brief in the legal challenge to the suspension. Our brief argues that the decision to suspend the rule was arbitrary and capricious because EPA focused only on amorphous compliance costs and ignored the effects of pollution that will continue to be discharged while the rule is suspended. As we explain in the brief, it is fundamentally irrational to make a decision based on such a one-sided analysis, and the suspension should be vacated.

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  • Comments to the Forest Service on Quantifying and Monetizing Greenhouse Gas Emissions

    June 20, 2017

    We recently submitted comments to the United States Forest Service on a Draft Environmental Impact Statement (EIS) that makes problematic claims about evaluating greenhouse gas emissions. In the Pine Mountain Late-Successional Reserve Habitat Protection and Enhancement Project Draft EIS, the Forest Service gives three main reasons for not quantifying—or monetizing the effects of—greenhouse gas emissions from the proposed action. First, the Service claims that “project level emissions alone are not sufficient to cause climate change.” Second, the Service claims that the “large majority of Forest Service projects” are too “small” for it to be “presently possible to conduct quantitative analysis of actual climate change effects.” Finally, the Service questions whether “such disclosure would provide a practical or meaningful effects analysis for project decisions.” We explain why each of these reasons is wrong according to economic principles, the requirements of the National Environmental Policy Act, and the Service’s own guidance regarding climate change.

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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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  • Public Comments

    Comments on California Electricity Policy

    May 26, 2017

    California’s state government is moving forward on electricity and climate policy, likely setting a blueprint for future state and federal action. We submitted comments to the California Public Utilities Commission (CPUC) on factual disputes flagged by stakeholders, related to how utilities will use cost-benefit analysis in decisionmaking. We encouraged staff at CPUC to use the Social Cost of Carbon for its interim greenhouse gas adder, use a 3% discount rate for future damages, include other environmental externalities like air pollution in its analysis, and continue considering societal costs to ensure that the benefits justify the costs of a proposed policy.

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  • Public Comments

    Comments on EPA’s Proposal to Further Delay the Amendments to the Risk Management Program

    May 19, 2017

    We recently submitted comments on the Environmental Protection Agency’s proposal to delay the effective date of EPA’s amendments to the Risk Management Program for twenty more months and to put off the compliance deadlines indefinitely. The original rule was issued under section 112®(7)(A) of the Clean Air Act and updated chemical accident prevention rules at manufacturing plants, after a fatal explosion at a fertilizer plant in West Texas.

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