Institute for Policy Integrity

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Project Updates

Viewing all updates in Public Comments
  • 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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  • Public Comments

    Comments to New York State on Clean Energy Standards for Existing Generators

    January 8, 2018

    New York State plans to provide support to some existing small hydro, wind, and biomass generation facilities at risk of closure, in order to prevent the state from backsliding on its ambitious clean energy goals. The New York Public Service Commission released a report on the Clean Energy Standard Tier 2 Maintenance program, which focuses on the criteria a generator should meet in order to receive financial support and how these payments should be determined. Our comments on the report encourage the Commission to harmonize these payments across all proposed review processes for Tier 2 generators.

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  • Public Comments

    Comments to the U.S. Fish and Wildlife Service on Market-Based Mitigation Programs

    January 5, 2018

    We recently submitted comments to the U.S. Fish and Wildlife Service on its market-based mitigation programs. Our comments were based in part on the recommendations Policy Integrity’s Legal Director, Jason Schwartz, made to the Administrative Conference of the United States on marketable permits, which were adopted in late December.

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  • Public Comments

    Comments to the Department of Labor on the Rescission of Tip Regulations

    January 5, 2018

    The Department of Labor recently proposed rescission of tip regulations under the Fair Labor Standards Act. We submitted comments explaining the Department’s failures, including to quantify important effects of the proposed rescission, to consider a range of realistic assumptions, or even to explain why the rescission’s purported benefits justify the total possible costs.

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  • Public Comments

    Comments on Arctic Drilling to the Bureau of Ocean Energy Management

    December 15, 2017

    We submitted comments on the Bureau of Ocean Energy Management’s environmental impact statement for potential offshore oil drilling and an undersea oil pipeline off Alaska’s northern coast. While expanded drilling in the Arctic presents many climate and public health concerns, BOEM did use the Social Cost of Carbon in assessing environmental impacts of the Liberty Development and Production Plan. Our comments encourage BOEM to continue using the best available methods for the Social Cost of Carbon in future environmental impacts statements, and we also recommended that BOEM use the Interagency Working Group’s Social Cost of Methane to quantify methane damages.

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  • Public Comments

    Comments on EPA Methane Rule Stay

    December 15, 2017

    The Environmental Protection Agency (EPA) recently paused certain requirements to reduce methane leaks and emissions from new oil and gas facilities. In its “notice of data availability” for the proposed stay, EPA claims that the compliance costs of reducing these emissions exceed the benefits to the public and to industry. Our comments argue that EPA manipulated economics to make this claim. EPA undervalued the social cost of methane emissions and claimed that the forgone benefits of the rule are only $5.4 to 23 million per year, when EPA’s original estimates said the rule would create public benefits of $140-180 million per year.

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  • Public Comments

    Public Comments on Regulatory Review (SBA, NCUA, FDA, DOT and USCBP)

    December 14, 2017

    Federal agencies continue to request 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. We also recommend that agencies develop prospective plans for regulatory review going forward. The agencies for which we recently filed comments include Small Business Administration, Department of Transportation, National Credit Union Administration, Food and Drug Administration, and Customs and Border Control Bureau.

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  • Public Comments

    Comments on the Clean Water Rule’s “Applicability Date”

    December 13, 2017

    The Environmental Protection Agency and Army Corp of Engineers’ newest attempt to delay implementation of the Clean Water Rule adds an “applicability date” to the original rule. Our comments to EPA argue that this “applicability date” is effectively an administrative stay of the Rule, which the Agency has no authority to issue. Moreover, delaying implementation of the Clean Water Rule will have substantial negative economic consequences, as detailed in our report on the rule. And the agencies have not provided an adequate justification for imposing these costs on society.

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