Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

  • Public Comments

    Comments to California on Its Cap and Trade Program

    March 16, 2018

    California has legislation authorizing its Air Resources Board (ARB) to extend its cap-and-trade program for carbon emissions. This extension, while defining much of the program’s structure, asks ARB to develop some design features through a regulatory process and public feedback. California’s most recent changes to the plan are consistent with our previous comments on the program, and they place California on the path to internalizing the cost of climate change from carbon emissions. Our most recent set of comments encourage ARB to continue to set the price ceiling for carbon permits at least as high as the Social Cost of Carbon set by the Interagency Working Group in 2016, as it does in its Concept Paper on carbon pricing. We also encourage ARB to allocate preferentially any unsold carbon allowances to the price ceiling, rather than to a lower price.

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  • News

    Helping California Improve Energy Decisionmaking

    March 14, 2018

    California has long been a trendsetter in clean energy policy, and our input helped inform the state’s approach for evaluating distributed energy resources (DERs), such as rooftop solar installations. The state’s new approach, which will quantify the environmental benefits of DERs, could help influence other policies around the country, boosting the growth of clean energy sources. Our comments to the California Public Utilities Commission were heavily cited in a March 2018 administrative law judge ruling, which, if adopted by the Commission, would require utilities to conduct a societal cost test to determine the cost-effectiveness of DERs.

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  • Court Filings

    Brief Challenging Suspension of NHTSA Rule on Fuel Economy Penalties

    March 12, 2018

    In 2017, the National Highway Traffic Safety Administration (NHTSA) suspended its 2016 Civil Penalties Rule, which adjusted the penalties for automobile manufacturer non-compliance with fuel economy standards for the first time in decades to reflect inflation. In issuing its suspension, NHTSA claimed that it was causing no harm. Our brief in the case challenging this suspension shows that NHTSA’s claim of no harm was inaccurate.

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  • Public Comments

    Comments on Use of the Social Cost of Greenhouse Gases in Environmental Impact Statements

    March 9, 2018

    We recently submitted joint comments to advocate for the proper use of the social cost of greenhouse gases in multiple environmental impact statements. Our comments to the Office of Surface Mining and Reclamation (OSMRE) and our comments to the Bureau of Land Management (BLM) focused on the agencies’ failure to use the social cost of greenhouse gases metric to account for the climate effects of anticipated project emissions. In our comments on the Bureau of Ocean Energy Management (BOEM)’s 5-year scoping plan for offshore oil and gas leasing, we emphasized that if and when BOEM decides to monetize greenhouse gas emissions, it should use the 2016 IWG estimates, as it has done in the past.

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  • Public Comments

    Comments on Interior’s Offshore Oil and Gas Leasing 2019-2024 Draft Proposed Program

    March 9, 2018

    The Department of the Interior’s offshore leasing program must analyze and account for the potential for environmental damage, the potential for the discovery of oil and gas, and the potential for adverse impact on the coastal zone. In addition, offshore oil and gas leases must provide fair market value for private use and development of these publicly-owned oil and gas resources. Our comments to the Interior’s Bureau of Ocean Energy Management (BOEM) explain why its Draft Proposed Program for 2019-2024, which would replace BOEM’s existing Program for 2017-2022, fails to meet its statutory mandates under the Outer Continental Shelf Lands Act (OCSLA).

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  • Public Comments

    Royalty Rate Changes for Offshore Drilling

    February 27, 2018

    At a meeting in Houston on February 28, the Interior Department’s Royalty Policy Committee recommended lowering the royalty rate that companies pay to the public when they drill for oil and gas in U.S. coastal waters. Such a change would go against the Interior Department’s statutory mandate to earn fair market value for the development of publicly owned natural resources. Our policy director, Jayni Hein, submitted public comments to the Royalty Policy Committee and spoke at the meeting.

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  • Public Comments

    Comments on Clean Power Plan Replacement Advanced Notice of Proposed Rulemaking

    February 27, 2018

    Though the Environmental Protection Agency plans to replace the Clean Power Plan, our recent comments to EPA reiterate that there is no compelling legal or economic case for repealing the Clean Power Plan or deviating from its flexible design. The Clean Power Plan is a permissible exercise of the EPA’s rulemaking authority under the Clean Air Act, is consistent with regulatory precedent, and is hugely cost-benefit justified.

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  • Public Comments

    Comments to the Regional Greenhouse Gas Initiative on Virginia’s Proposal

    February 9, 2018

    As part of its climate plan, the State of Virginia proposes to join the Regional Greenhouse Gas Initiative (RGGI), a carbon trading program currently including states across the Northeastern US. We submitted comments to RGGI on how it can incorporate Virginia into the program and reduce carbon emission in a cost-effective way. RGGI should carefully assess the effect that Virginia’s initial carbon allowance level will have on the RGGI cap. Adding Virginia electricity generators to RGGI will improve electricity market efficiency. The exact extent of those improvements will be affected by the windfall revenue that Virginia’s power producers may receive through the unique consignment auction process for the allowances. RGGI should therefore ensure that the possibilities for windfall are minimized for Virginia’s regulated power producers.

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  • Public Comments

    Comments to Colorado Public Utilities Commission on Electric Resource Planning

    January 31, 2018

    The Colorado Public Utilities Commission is revising their electricity resource planning process. Our comments to the Commission suggest legal language for incorporating externalities, like the climate effects of greenhouse gas emissions, into the state’s electricity policy. We also explain why the Social Cost of Carbon, as developed by the federal government in 2016, is the best tool for incorporating the externalities of carbon emissions into policy. Our response comments rebut the state electric utility’s faulty arguments against using the social cost of carbon in this process, and supports the use of cost-benefit analysis in determining the best policy option.

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  • Public Comments

    Comments to Interior on Offshore Drilling Safety Requirements

    January 29, 2018

    The Bureau of Safety and Environmental Enforcement (BSEE) within the Department of the Interior is tasked with setting safety and environmental standards for offshore oil and gas production and exploration in federal waters. While BSEE updated its safety requirements in 2016, it now proposes to weaken and repeal some of these safety requirements in order to encourage more oil and gas production. In our comments on the proposed rule, we argue that the agency has failed to provide a reasoned explanation for repealing these requirements, which were part of a comprehensive update to safety regulations that had not been revised since 1988.

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