Institute for Policy Integrity

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What We Do

Project Updates

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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 to FERC in response to their Notice Inviting Comments, and we have now submitted reply comments.

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  • Public Comments

    Comments on Delay of BLM Waste Prevention Rule

    November 6, 2017

    In September 2017, a federal court overturned the Bureau of Land Management’s (BLM’s) decision to delay a rule that is designed to prevent private industry from wasting natural gas resources in mining activities on public land. In its decision to delay the rule, BLM had not considered the benefits that would be forgone. Now, BLM has proposed a second delay. Our comments to BLM argue that the agency manipulated the calculation of forgone benefits from delay—particularly, the calculation of the social cost of methane—in ways that are completely inconsistent with the best available science, the best practices for economic analysis, and the legal standards governing rational decisionmaking. The 2016 Waste Prevention Rule’s benefits exceed its costs by as much as $200 million per year, and thus the proposal to suspend the rule is arbitrary and capricious.

    We filed these joint comments with the Environmental Defense Fund, the Natural Resources Defense Counsel, the Sierra Club, and the Union of Concerned Scientists.

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  • Court Filings

    Brief on EPA Chemical Disaster Rule Delay

    November 1, 2017

    EPA recently delayed the effective date of a rule that would have decreased the severity and number of chemical accidents at manufacturing facilities and refineries. State and NGO plaintiffs sued EPA over the delay, arguing that EPA did not have statutory authority to issue it, and that the delay was arbitrary and capricious. We filed a brief in support of petitioners arguing that EPA did not offer an adequate explanation for choosing to forgo the benefits of the chemical disaster rule.

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  • Public Comments

    Providing Information for DOE’s Net Metering Study

    October 30, 2017

    Net metering, the predominant approach to compensating distributed solar generation in the U.S., essentially pays households with solar panels a flat retail rate for every kilowatt hour they send back to the grid. In response to the Department of Energy’s request for information on the costs and benefits of net energy metering, we submitted Richard Revesz and Burcin Unel’s law review article on net metering and distributed electricity generation. The paper analyzes the benefits and costs of distributed generation, and identifies ways for state policy to better match consumer compensation for solar generation with the energy system and environmental benefits that it provides. It also includes information that is relevant to the RFI including the identification and categorization of the costs and benefits of net energy metering policies.

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  • Court Filings

    Brief on Department of Education’s Borrower Defense Rule

    October 25, 2017

    Under Secretary Betsy DeVos, the Department of Education delayed implementation of the Borrower Defense Rule, which would have helped students who have been defrauded by for-profit educational institutions discharge their federal student loans. In our amicus brief supporting borrower and state challenges to the delay, we argue that the Department violated the Administrative Procedure Act by arbitrarily disregarding the benefits for student borrowers that would be forgone as a result of the delay.

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  • Court Filings

    Brief on Wyoming Natural Gas and Oil Leases

    October 25, 2017

    Wildearth Guardians and Physicians for Social Responsibility recently sued the Bureau of Land Management over its leasing of lands in Wyoming for natural gas and oil extraction. In our amicus brief in support of the legal challenge, we argue that the agency’s decision to trumpet the benefits of the leasing decisions while also failing to quantify the greenhouse gas emissions that will result from these leases (and failing to use the social cost of carbon to assess the impact of those emissions on society) violated the National Environmental Policy Act.

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  • Public Comments

    Comments to the Federal Energy Regulatory Commission on Grid Reliability and Resilience Pricing

    October 23, 2017

    Energy Secretary Rick Perry’s controversial proposal to subsidize coal and nuclear plants could have terrible consequences for consumers and public health, as our recent comments and op-ed in US News highlight. In September, Perry asked the Federal Energy Regulatory Commission (FERC) to adopt a new rule that would guarantee coal and nuclear plants their full costs plus a profit, so long as they keep 90 days of fuel on site. Perry claims that these “fuel-secure” plants ensure grid reliability and resilience, but neither he nor FERC adequately define these terms or explain why such a measure is justified.

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  • Public Comments

    Comments on Reconsideration of NHTSA Rule to Update Civil Penalties

    October 10, 2017

    In December 2016, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that updates civil penalties for car manufacturers that violate fuel economy standards. NHTSA is now reconsidering the rule, claiming it would have a significant negative economic impact. The agency provides no evidence that economic circumstances have changed since the rule’s finalization to make the rule more costly. Our comments argue that the agency should not proceed with the proposed reconsideration, because it inadequately explained why it changed positions. If the agency does continue with the reconsideration, both the Inflation Adjustment Act and economic cost-benefit analysis would justify an update to the penalties rates rather than maintaining the original penalty rate from 1975.

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  • Public Comments

    Public Comments on Regulatory Review (CFTC, CPSC, Department of Education, PBGC, USDA)

    October 4, 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.

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  • Public Comments

    Joint Comments on Fuel Economy Standards and the Social Cost of Greenhouse Gases

    September 25, 2017

    Vehicle fuel economy standards set by the National Highway Traffic and Safety Administration (NHTSA) help reduce greenhouse gas emissions in the United States by making cars more fuel efficient. Our comments on the reconsideration argue that NHTSA should value the social cost of those emissions as robustly as possible, as they have done in the past. We encourage NHTSA to consider the social cost of greenhouse gases in both the rule’s Environmental Impact Statement and Regulatory Impact Analysis, and that it should use estimates considering global damages of climate change using a three percent or lower discount rate.

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