Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

Viewing all updates in Natural Resources
  • Public Comments

    Comments to EPA on the Clean Water Rule

    October 9, 2017

    In our recent comments on the attempted repeal of EPA’s Clean Water Rule, we show how the EPA and Army Corps of Engineers obscured the value of wetlands protection in their proposal to repeal the rule.

    Read more

  • Public Comments

    Comments to Interior’s Royalty Policy Committee

    October 9, 2017

    On behalf of Policy Integrity, Policy Director Jayni Hein recently delivered a statement at the Department of Interior’s Royalty Policy Committee public meeting on October 4, 2017. Her statement included recommendations on how Interior can achieve “fair market value” for taxpayers for the use and development of federal resources, as well as how Interior can fulfil its “multiple use” mandate.

    Read more

  • Public Comments

    Comments on Hydraulic Fracturing Rule Rescission

    September 25, 2017

    In proposing to rescind its two-year-old rule for managing hydraulic fracturing operations on federal and tribal lands, the Bureau of Land Management (BLM) fails to explain why the rescission’s estimated cost savings to industry justify the forgone benefits, such as environmental protection and increased worker safety. Our comments to BLM on the proposed rescission discuss the agency’s inadequate cost-benefit analysis, which does not sufficiently explain why changed circumstances in the past two years have altered the rule’s cost-benefit justification.

    Read more

  • Public Comments

    Public Comments on Regulatory Review (Treasury, GSA, FEMA, State, DOJ, FCA, Interior)

    August 15, 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.

    Read more

  • 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.

    Read more

  • 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.

    Read more

  • News

    Hein Testifies at House Hearing on Offshore Leasing

    July 7, 2016

    On July 6, Jayni Hein testified at a House Natural Resources Committee hearing on the “Innovation in Offshore Leasing Act.” The hearing, held by the Subcommittee on Energy and Mineral Resources, focused on H.R. 5577, a bill that would amend the Outer Continental Shelf Lands Act to allow internet-based offshore oil and gas lease sales, among other measures. Hein’s testimony covered four main topics, suggesting that the Department of the Interior should: continue to increase transparency and public participation in the offshore leasing process; improve the regulations that underlie the Bureau of Ocean Energy Management’s (BOEM’s) five-year planning process; build on recent progress addressing environmental, social, and economic uncertainty in its five-year Program and lease sales; and advance efforts to account for the environmental and social costs of fossil fuel leasing through royalty rate and other fiscal reform. Hein’s testimony elaborated on some of the arguments from her recent Alaska Law Review article and recent comments to BOEM.

    Read more

  • News

    Coal Reform Publications, Workshop for Policymakers

    July 1, 2016

    As the Department of the Interior continues its review of the federal coal leasing program, we recently released two new publications on coal reform and hosted a related workshop for government officials.

    Read more

  • Public Comments

    Comments on Proposed Offshore Leasing Program for 2017-2022

    June 16, 2016

    We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values.

    Read more

  • Public Comments

    Comments on BLM Rule to Control Fugitive Methane Emissions

    April 22, 2016

    We recently submitted two sets of public comments to the Bureau of Land Management (BLM) regarding a proposed rule to reduce waste of natural gas from venting, flaring, and leaks during oil and gas production on federal and Indian lands. BLM has proposed making natural gas lost through these processes subject to royalty payments.

    Read more