Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

  • Public Comments

    Comments to EPA on Evaluating Existing Regulations

    May 15, 2017

    We recently submitted comments to the Environmental Protection Agency (“EPA”) regarding its obligation to evaluate existing regulations and identify some for repeal, replacement, or modification under Executive Order 13,777. Our comments are meant to ensure that EPA stays focused on its objective to identify outdated, unnecessary, ineffective, or net-costly regulations for repeal, replacement, or modification and does not prioritize recently promulgated and overwhelmingly cost-benefit justified rules, some of which have been targeted by industry commenters.

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  • Resources on Congressional Regulatory Bills

    May 15, 2017

    The House of Representatives has passed several bills that could have devastating effects on the federal regulatory process. To help journalists and policymakers understand the potential impact of some bills currently moving through Congress, we recently published a series of fact sheets.

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  • Public Comments

    Comments to the Office of Natural Resources Revenue on the Reform Rule

    May 5, 2017

    We recently submitted two sets of comments to the Office of Natural Resources Revenue (ONRR), making the case against repealing an Obama-era reform that promised to recover millions of dollars in royalties from mining companies—a reform that would have ensured that taxpayers receive fair market value for the use of public lands. Our first set of comments objects to the proposed repeal of the Consolidated Federal Oil & Gas and Federal & Indian Coal Valuation Reform Rule (the “Reform Rule”), while our second set responds to ONRR’s request for comments on whether revisions are necessary to the regulations governing coal, oil, and gas royalties. We previously submitted comments to ONRR on the proposed Reform Rule.

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  • Public Comments

    Comments on U.S. Army Corps of Engineers Environmental Impact Statement

    April 28, 2017

    President Trump’s recent executive order on energy disbands the Interagency Working Group on the Social Cost of Carbon (IWG) and withdraws its technical support documents that underpin the IWG’s range of estimates. Instead, the executive order directs federal agencies to continue to monetize the social cost of carbon emissions pursuant to the Office of Management and Budget’s Circular A-4. In our comments, we highlight that the range of estimates from the IWG that agencies have been using, including the number used by the U.S. Army Corps of Engineers in the Draft Environmental Impact Statement, is consistent with Circular A-4 and therefore, consistent with the executive order.

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  • Public Comments

    California Public Utilities Commission- Comments on Interim Greenhouse Gas Adder

    April 26, 2017

    We recently submitted comments to the California Public Utilities Commission on their proposal for an interim greenhouse gas adder. The proposal was for an adder that starts at $0 in 2017 and increases linearly to $250 in 2030. We support the use of a greenhouse gas adder. However, our comments suggest that the Commission instead use an adder based on the Interagency Working Group’s Social Cost of Carbon (“SCC”).

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  • Public Comments

    California Air Resources Board – Comments on the 2017 Scoping Plan Update

    April 13, 2017

    We recently submitted a second set of comments to the California Air Resources Board on its 2017 Climate Change Scoping Plan Update. These comments build on those we submitted in December to ARB on the discussion draft of the scoping plan.

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  • Public Comments

    Department of Commerce – Comments on Manufacturing and Regulation

    April 11, 2017

    We recently submitted comments to the Department of Commerce in response to its request for information on the impact of federal regulations on domestic manufacturing. The DOC requested comments on ideas for retrospective review of permitting and regulatory requirements, with a focus on repealing existing “burdensome” requirements. The agency also sought information about the potential adverse impacts of regulations on manufacturing.

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  • Public Comments

    Comments on California’s Evaluation Methods for Distributed Energy Resources

    March 23, 2017

    We recently submitted comments to the California Public Utilities Commission (CPUC) on their proposal to develop a more robust societal cost test to evaluate the cost-effectiveness of distributed energy resources (DERs). California has been a national leader in addressing the challenges associated with DER integration, and this proceeding will help the state to reform their cost-effectiveness framework.

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  • Public Comments

    Toxic Substances Control Act Comments

    March 21, 2017

    We recently submitted two sets of comments to the Environmental Protection Agency (EPA) on issues related to the implementation of the recently amended Toxic Substances Control Act (TSCA). The first comment letter focuses on EPA’s proposed restrictions on the manufacture, processing, and distribution of trichloroethylene (TCE) for use in aerosol degreasing and in spot cleaning in dry cleaning facilities. Our second comment letter focuses on EPA’s proposed process for conducting future risk evaluations under the amended TSCA.

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  • Public Comments

    Comments on California’s Clean Cars Program

    March 20, 2017

    We recently submitted comments on the California Air Resource Board’s (ARB’s) Midterm Review of its Advanced Clean Cars program, which sets pollution limits and zero-emissions vehicle targets for automobiles sold in California. California is unique among the states in that the Clean Air Act allows it to seek a waiver from EPA to set its own automobile emission targets, which other states can then adopt.

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