Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

  • Letters

    Joint Letter to the House Committee on Natural Resources on the Social Cost of Carbon

    November 30, 2017

    We recently submitted a joint letter, coauthored by several environmental groups, to the House Committee on Natural Resources about the “Transparency and Honesty in Energy Regulations Act of 2017.” This act, H.R. 3117, seeks to direct agencies to ignore or drastically undervalue climate damages, and would seriously hamper future use and development of economically and scientifically sound estimates for the Social Cost of Carbon. This would result in federal government decisionmaking that fails to adequately account for the enormous social and economic consequences of climate change. In the letter, we urge the Committee to reject this and any other attempt to weaken, minimize or eliminate the requirement that agencies take into account the cost of climate change.

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  • Public Comments

    Comments to the Public Utilities Commission of Nevada on the Social Cost of Carbon

    November 30, 2017

    Nevada recently passed SB 65, a bill updating the state’s electricity planning process and boosting resources that provide economic and environmental benefits to the state. The Public Utilities Commission of Nevada subsequently held a series of formal and informal workshops and calls to shape the new regulation required under SB 65. We submitted joint comments with other stakeholders that included consensus language for several sections of the regulation. We also note in these comments that while stakeholders did come to an agreement on most issues, questions remain on how to define the social cost of carbon for the implementing regulation. Accordingly, we submitted supplemental comments to the PUC, discussing how the social cost of carbon is used by several other states, including in state electricity regulations and proceedings. We note that Colorado, Illinois, Maine, Minnesota, and New York use SCC estimates from the federal Interagency Working Group, and recommend that the Nevada PUC follow a similar approach.

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  • Court Filings

    Amicus Briefs on New York’s Zero Emissions Credits

    November 28, 2017

    Policy Integrity submitted two amicus briefs to the U.S. Court of Appeals for the Second Circuit on New York’s Clean Energy Standard and Zero Emissions Credits, defending the state’s policy.

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  • Public Comments

    Comments to FERC on the Southeast Market Pipelines project supplemental EIS

    November 21, 2017

    We submitted comments to the Federal Energy Regulatory Commission (FERC), along with partners, on the Commission’s failure to use the social cost of greenhouse gases in the Southeast Market Pipelines Project supplemental environmental impact statement. In addition to the joint comments, we also submitted a set of comments on FERC’s failure to conduct a full assessment of substitute energy sources.

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  • Public Comments

    Comments to Highway Administration and Army Corps on Addressing Greenhouse Gas Emissions

    November 16, 2017

    We submitted comments to the Federal Highway Administration (FHWA) and the US Army Corps of Engineers (USACE) on recent draft environmental impact statements (EISs), in which we stressed the importance of addressing climate impacts of proposed projects.

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  • Public Comments

    Comments on the Federal Highway Administration’s Proposed Repeal of the Greenhouse Gas Measure

    November 14, 2017

    The Federal Highway Administration (FHWA) has announced its intention to repeal the greenhouse gas (GHG) measure, which is part of a series of rulemakings intended to ensure the most efficient investment of federal transportation funds. We submitted comments to the FHWA on the proposed repeal, highlighting that the Administration had failed to consider foregone benefits in its decision to finalize the repeal and failed to explain why the benefits of the measure no longer justify the costs.

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  • Court Filings

    Brief on HUD’s Suspension of Housing Voucher Reform

    November 13, 2017

    The Department of Housing and Urban Development (HUD) recently suspended a rule to increase the availability of affordable housing in higher-rent neighborhoods. Our amicus brief in a suit against HUD argues that the suspension violates administrative law by disregarding economic impacts and failing to first seek public feedback.

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  • Public Comments

    Comments on the Work Plan of the New York Carbon Pricing Task Force

    November 10, 2017

    The New York Independent Systems Operator (NYISO) and the New York Department of Public Service (DPS) recently began a joint effort to harmonize the state’s energy policies with the operation of wholesale markets, including by establishing a task force to discuss how to incorporate carbon pricing into the wholesale market. We recently submitted comments with a number of recommendations on how to ensure the task force’s work plan shapes the program in the most economically efficient and legally sound way. We suggested that price, revenue allocation, leakage, and harmonization with other state policies be included as topics in the work plan, among several others. We plan to continue to engage with this process over the next several months.

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  • Public Comments

    Comments on California’s Cap-and-Trade program

    November 8, 2017

    This summer, California passed Assembly Bill 398, extending the state’s well-regarded cap-and-trade program until 2030. The California Air Resources Board held a public workshop on October 12, 2017, on implementing the provisions of AB 398. The Board requested feedback on a number of specific issues to aid it in finalizing the cap-and-trade regulations, including on setting a price ceiling for emissions allowances and unsold allowance allocation. In our comments to the Board, we focused on these two issues, making recommendations for developing regulations under AB 398 that help ARB fulfill its statutory mandates to take into account the externalities associated with greenhouse gas emissions and promote overall societal well-being.

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  • Public Comments

    Reply Comments to FERC on Grid Reliability and Resilience Pricing

    November 8, 2017

    In September, Energy Secretary Perry asked the Federal Energy Regulatory Commission (FERC) to adopt a new rule that would guarantee plants with 90-day on-site fuel, mostly coal and nuclear plants, full cost recovery. We submitted an initial set of comments in response to their Notice Inviting Comments, and we have now submitted reply comments.

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