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Recent Projects

  • Public Comments

    Comments to Rhode Island on Carbon Pricing Study

    May 28, 2020

    Rhode Island is undertaking a study to understand what a state carbon pricing scheme would look like and how it would interact with the state’s participation in the Regional Greenhouse Gas Initiative and the Transportation and Climate Initiative. We submitted comments that support the exploration of implementing a multisectoral carbon price and recommend that the state study a scenario that uses the federal Interagency Working Group’s Social Cost of Carbon.

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  • Policy Briefs

    What We Lose When They “Save”

    May 28, 2020

    The Trump administration regularly boasts about the cost savings of rolling back regulations, focusing on industry profits without considering significant negative impacts. This policy brief address and counters the administration's cost savings claims and demonstrates that they should not be taken at face value.

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  • Issue Briefs

    Carbon Pricing in Wholesale Energy Markets

    May 26, 2020

    Policy Integrity and the Nicholas Institute for Environmental Policy Solutions at Duke University convened a conference on March 3, 2020, to discuss current, and potential future, approaches to carbon pricing in wholesale markets. This brief highlights some of the major points of discussion and suggests open questions for future study. 

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  • Court Filings

    Amicus Brief on Navigable Waters Protection Rule

    May 21, 2020

    In April, the Environmental Protection Agency (EPA) and Army Corps of Engineers published the Navigable Waters Protection Rule, which considerably restricts the waters and wetlands that are federally protected under the Clean Water Act. We filed a brief in the Northern District of California focusing on the agencies’ economic analysis, which the agencies use to obscure the rule’s anticipated harms.

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  • Issue Briefs

    Understanding EPA’s Enforcement and Compliance Policy During the COVID-19 Pandemic

    May 21, 2020

    This issue brief summarizes EPA's enforcement and compliance policy in light of COVID-19, describing its significance and clarifying its contours. The policy opens the door to potentially problematic and harmful actions, especially on a short-term basis. 

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  • Public Comments

    Comments to EPA Science Advisory Board on Economic Analysis Guidelines

    May 20, 2020

    The Environmental Protection Agency’s chartered Science Advisory Board (SAB) invited the public to comment on its new draft Guidelines for Preparing Economic Analyses. We submitted multiple sets of comments covering different portions of the guidelines. 

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  • Public Comments

    Comments to New Jersey BPU on Resource Adequacy Alternatives

    May 20, 2020

    The New Jersey Bureau of Public Utilities (BPU) requested public input on its investigation of resource adequacy alternatives. We submitted comments encouraging the New Jersey BPU to recognize important uncertainties affecting the proceeding, consider a broad range of costs of pursuing a Fixed Resource Requirement, and explore the possibility of a carbon pricing program in addition to participation in the Regional Greenhouse Gas Initiative.

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  • Public Comments

    Joint Comments to CTFC on Climate-Related Market Risk

    May 14, 2020

    The Commodity Futures Trading Commission (CTFC) requested public input on issues relevant to its Climate-Related Market Risk Subcommittee. We submitted joint comments highlighting the significant financial risks that climate change poses and emphasizing that an economy-wide price on carbon emissions is the regulatory tool that will be the most effective in mitigating a climate-related financial crisis.

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  • Public Comments

    Comments to PHMSA on Data Collection from Pipeline Accidents

    May 8, 2020

    The Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing to gather additional data on pipeline accidents and fires, including data on injuries, property damage, and loss of natural gas. We submitted comments supporting PHMSA’s efforts to better assess the social cost of accidents and encouraging the agency to estimate greenhouse gas emissions that result from pipeline fires.

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  • Public Comments

    Comments to SEC on Regulation S-K and Climate Risk

    April 28, 2020

    The Securities and Exchange Commission (SEC) proposed a rule modifying Regulation S-K, which governs reporting requirements for public companies. We submitted comments focusing on the SEC’s failure to require disclosure of risks relating to climate change. Climate risks are economy-wide impacts in which the future increasingly diverges from past experience, and predicting such risks requires more granular data than is typically disclosed in financial reporting. We suggest that the SEC adopt a more specific line-item approach to climate risk reporting, similar to the framework suggested under the Task Force on Climate-Related Financial Disclosures.

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