Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

  • 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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  • Public Comments

    Comments to Massachusetts Department of Environmental Protection on Greenhouse Gas Reductions

    March 1, 2017

    The Massachusetts Department of Environmental Protection (“MassDEP”) has proposed a set of regulations to limit the greenhouse gas emissions from electric power plants, natural gas pipelines, government-owned transportation equipment, and utility-owned switchgear equipment. MassDEP has also proposed a new requirement that retail sellers of electricity purchase gradually increasing amounts of clean energy, along with non-binding targets for greenhouse gas emissions from the transportation sector.

    In our comments to MassDEP, we offer three suggestions to ensure these regulations cut global greenhouse gas emissions in a cost-effective way. First, we encourage MassDEP to prevent potential emissions leakage to other states in the Northeast’s Regional Greenhouse Gas Initiative (“RGGI”) program. Second, we recommend the regulations should be technology-neutral and use a flexible compliance system. Third, we recommend enforceable emissions limits on the transportation sector rather than non-binding targets, especially considering that the state’s emissions from transportation sector are almost twice those of the electric sector.

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  • Public Comments

    Public Comments to OIRA on Regulatory Review Guidance

    February 10, 2017

    President Trump’s recent Executive Order on reducing regulation directed agencies to identify two existing regulations to repeal when issuing a new regulation, and to offset all incremental costs of new regulations. On February 2, 2017, the Office of Information and Regulatory Affairs (OIRA) released interim guidance on how it plans to implement the Executive Order, and we submitted comments on the guidance.

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  • Public Comments

    Energy Storage Comments to FERC

    January 30, 2017

    In November 2016, the Federal Energy Regulatory Commission (FERC) announced its intent to ease the process for energy storage and distributed energy resources to participate in wholesale electricity markets. The proposed rule would require regional transmission organizations (RTOs) and independent system operators (ISOs) to revise their tariffs to energy providers in order to promote technology neutrality. In comments on the rule, we recommend that in addition to adjusting these tariffs, FERC should take more steps to fully realize the benefits that these technologies could provide for wholesale markets. We recommend that the Commission explicitly clarify the benefits for which it compensates these technologies; allow states to compensate for distribution-side benefits; eliminate location-based constraints on resource participation while recognizing the importance of location in optimally dispatching these services; encourage coordination between RTOs/ISOs and state regulators; and promote advanced metering technology to increase efficiency in how energy is dispatched.

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  • Court Filings

    Policy Integrity Files Brief in Case Challenging EPA’s Mercury and Air Toxics Standards

    January 25, 2017

    In 2012, EPA issued the Mercury and Air Toxics Standards (MATS), which limit coal- and oil-fired power plants’ emissions of mercury and other hazardous air pollutants. In their most recent challenge to the rule, Petitioners seek to obscure the fact that regulating power plants’ emissions of hazardous air pollutants overwhelmingly benefits society by asking the U.S. Court of Appeals for the D.C. Circuit to ignore or discount large portions of EPA’s analysis—namely, its consideration of indirect benefits (sometimes called ancillary benefits or co-benefits) and unquantified benefits. But, as our amicus brief points out, EPA’s consideration of indirect benefits and unquantified direct benefits is consistent with the Clean Air Act, past court decisions, federal cost-benefit guidelines, economic best practices, and regulatory precedent. Overall, we argue that the agency’s cost-benefit analysis was properly conducted and more than satisfies its obligation to consider costs when determining whether regulation of power plants’ hazardous emissions is “appropriate and necessary.”

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  • Court Filings

    Brief for Challenge to EPA’s Carbon Standards for New Power Plants

    December 25, 2016

    The EPA’s Carbon Pollution Standards for New Power Plants limit carbon dioxide emissions from new, modified, and reconstructed plants. A group of state attorneys general and energy companies have filed suit challenging the standards on several grounds. Policy Integrity submitted an amicus brief in support of EPA.

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