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  • A Roadmap to Regulatory Strategy in an Era of Hyper-Partisanship Cover

    A Roadmap to Regulatory Strategy in an Era of Hyper-Partisanship

    This report discusses how an administration that begins a new term can navigate regulatory strategy. It offers advice on navigating this terrain for White House officials, the Office of Information and Regulatory Affairs, transition teams at agencies, and advocates. The report also contains a section on how an incoming administration can roll back the prior administration’s rules if there is an inter-party transition.

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  • BLM Cancels Oil and Gas Lease Sale in Utah’s Moab Region

    The Bureau of Land Management (BLM) announced its decision to exclude 87,000 acres of public lands from an upcoming lease sale, agreeing with arguments raised by policymakers and environmental advocates, including Policy Integrity, that these public lands are too valuable for other uses to be designated for fossil fuel extraction.

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  • Markets, Externalities, and the Federal Power Act: The Federal Energy Regulatory Commission's Authority to Price Carbon Emissions Cover

    Markets, Externalities, and the Federal Power Act: The Federal Energy Regulatory Commission’s Authority to Price Carbon Emissions

    Article revised for the Environmental Law Reporter

    This article, excerpted from Davis Noll and Unel’s article in the NYU Environmental Law Journal, provides a comprehensive economic framework to show that addressing the CO2 externality through a carbon price falls within FERC’s authority to ensure an efficient market.

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  • Comments to New Jersey on Cost Test Straw Proposal

    The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. We submitted comments encouraging BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. We also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal. 

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  • Comments to EPA on Proposal for Cost-Benefit Analysis and the Clean Air Act

    We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.

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  • Amicus Brief in D.C. Circuit on Tennessee Pipeline Extension

    If constructed, the Tennessee pipeline extension and related projects would be responsible for substantial greenhouse gas emissions. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to quantify the project’s emissions and monetize climate damages using Social Cost of Carbon estimates is arbitrary.

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  • Amicus Brief in Appeal of Conscience Protections Decision

    Last fall, three federal courts—in the Southern District of the New York, the Northern District of California, and the Eastern District of Washington—vacated the Department of Health and Human Services’ conscience rule, which sought to expand healthcare providers’ rights to deny care on religious or moral grounds. In amicus briefs supporting the vacatur, Policy Integrity criticized HHS for, among other things, failing to consider the new policy’s likely health costs for women and LGBT individuals.

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  • Comments to Department of Labor on Rule Limiting ESG Investments

    The Department of Labor proposed a rule that would impose limitations on investors’ ability to choose investments in Environmental Social and Governance (ESG) strategies. We worked with the Environmental Defense Fund to submit comments focusing on the proposal’s flaws.

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  • New Mexico PRC Adopts Plan to Replace San Juan Coal Plant with Renewables Portfolio

    In 2022, New Mexico’s largest utility company will retire the San Juan Generating Station, a coal-burning power plant that has operated since 1973. In light of the decision, the state’s Public Regulatory Commission (PRC) has adopted a plan to replace the plant’s power output with 100 percent renewable energy and battery storage. The plan is a significant victory for the community groups and environmental advocates that have pushed to expedite the clean energy transition, and our efforts helped pave the way for this decision.

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  • Comments to Virginia on Developing an Energy Storage Rule

    The Virginia State Corporation Commission asked for input in advance of developing a rule for energy storage deployment. Our comments note that energy storage deployment can increase emissions from the electricity sector, even if those deployments also facilitate the integration of variable renewable resources. We urge the Commission, under the Virginia Clean Economy Act, to adopt a rule ensuring that energy storage resources are deployed and operated in ways that reduce net emissions.  

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