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Recent Projects

  • Comments to EPA on Proposal to Strengthen the Mercury and Air Toxics Standards

    In April 2023, the Environmental Protection Agency (EPA) proposed to strengthen and update the National Emission Standards for Hazardous Air Pollutants for coal- and oil-fired power plants, also known as the Mercury and Air Toxics Standards (MATS). In this proposal, EPA clearly explained why it revised the technology review conducted in 2020 and made the emissions standards more stringent on the basis of developments in control technologies. In our comments, we recommended improvements to the proposed update and highlighted areas where EPA's analysis succeeded.

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  • Ünel Named to Advisory Council for New York Electric Grid Operator

    The New York Independent System Operator (NYISO) has appointed Policy Integrity’s Executive Director, Dr. Burçin Ünel, to serve on its Environmental Advisory Council. The Council provides NYISO with information, analysis, and expert perspectives on state and federal environmental policies to help it better achieve its mission of maintaining reliability of the bulk electric system and administering competitive wholesale electricity markets. In her role on the Council, Dr. Ünel will use her expertise in utility regulation and energy policy to help NYISO build and maintain New York's “grid of the future.”

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  • Comments to OMB on Draft Update of Circular A-4

    This spring, the Office of Management and Budget (OMB) proposed a comprehensive update to the federal guidance document on best practices for conducting benefit-cost analysis, known as Circular A-4. Jointly with thirteen other nonprofit groups, we submitted comments commending particular aspects of the update and offering suggestions for further improvement.

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  • Joint Comments to EPA on Proposed Heavy-Duty Vehicles Rule

    In April, the Environmental Protection Agency released a proposal to reduce greenhouse gas emissions from heavy-duty vehicles beginning in model year 2027. Jointly with six other organizations, we submitted comments on EPA’s application of the social cost of greenhouse gases in that rule. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards. We also suggest that EPA apply additional analysis to the rule and all alternatives using draft updated climate-damage valuations that EPA released in November 2022.

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  • Comments to the New York Public Service Commission on Medium- and Heavy-Duty Electric Vehicle Charging

    Together with Resources for the Future, we submitted comments to the New York Public Service Commission in response to questions posed by the Commission about addressing barriers to medium- and heavy-duty electric vehicle charging. Our comments focus on the possibility for managed charging to reduce infrastructure needs and on additional considerations to optimize emissions outcomes. Our comments are centered around depot charging and draw on research that examines fleet charging needs in a depot setting.

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  • Comments to EPA on Proposed Rule to Strengthen Power Plant Effluent Guidelines

    In March, the Environmental Protection Agency (EPA) proposed to strengthen its power plant effluent guidelines by tightening discharge requirements for flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate resulting from steam electricity generation. In our comment letter, we offer several recommendations for EPA to strengthen its consideration of regulatory benefits. 

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  • US Benefit-Cost Analysis Requires Revision Cover

    US Benefit-Cost Analysis Requires Revision

    Letter in SCIENCE Supporting Proposed Adjustment to Discount Rates in Circular A-4

    A critical input in cost-benefit analysis is the discount rate, which determines how much impacts in the future are weighted relative to impacts in the present. Federal guidance currently calls on U.S. agencies to apply discount rates of 3% and 7%. But these rates, particularly the 7% rate, substantially devalue impacts that accrue to future generations, thus putting a thumb on the scale against policies that provide long-term benefits such as environmental and public-health regulation. In April, the Office of Management and Budget (OMB) proposed a comprehensive update to that guidance document, known as Circular A-4. Among other revisions, the draft would update the default discount rate used in federal regulatory analysis to 1.7%. In a letter published in Science, leading global experts on discount rates and cost-benefit analysis support the proposed revision.

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  • Letter to Treasury Department on the Use of Carbon Matching for Hydrogen Tax Credits

    Along with seven partners, we submitted a letter to the Department of the Treasury about the best methodology for determining lifecycle greenhouse gas emissions of hydrogen production when calculating the applicable amount of the 45V production tax credit (PTC). The letter had two primary purposes: (1) if local hourly energy matching is adopted as part of 45VPTC implementation, to highlight the critical importance of defining “local” in such a way that avoids increasing carbon emissions, and (2) to advocate for carbon matching as a more cost-effective and scalable alternative compliance pathway that also solves the problem that local hourly energy matching addresses.

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  • FERC Environmental Justice Roundtable Comments

    The Federal Energy Regulatory Commission (FERC), the agency responsible for regulating interstate energy infrastructure and markets, is seeking to better incorporate environmental justice into its decision-making. On March 29th, 2023, FERC held its first-ever Environmental Justice Roundtable where Policy Integrity’s Environmental Justice Director, Al Huang, testified and provided suggestions on how the Commission can identify, avoid, and minimize adverse impacts on environmental justice communities. We submitted additional comments to FERC on these issues, as well as on FERC's legal authority to incorporate environmental justice into its permitting decisions.

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  • Comments to FERC on its Backstop Siting Authority

    Following the passage of the Bipartisan Infrastructure Law, the Federal Energy Regulatory Commission (FERC) proposed implementing regulations for its authority to site transmission projects that have been rejected or not acted upon by states. We filed comments advising FERC that, to make these determinations and satisfy FERC's obligations under the National Environmental Policy Act, the Commission must consider how proposed transmission projects would affect emissions from power plants. Our comments further recommend improvements to the proposed rule's environmental justice provisions, which also relate to FERC's obligation to ensure that proposed projects are consistent with the public interest.

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