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Recent Projects

  • Comments to SEC on Investment Company Names

    The SEC has proposed a rule that would better align the names of investment companies with investor expectations, including for Environmental, Social, and Governance (ESG) investment funds, by requiring portfolio distribution requirements for funds whose name connotes a particular investment strategy. We submitted comments on the SEC's economic analysis of the Proposed Rule. We commend the Commission for complying with relevant case law and internal guidance on cost-benefit analysis and recommend steps that the SEC could take in the final rule to provide additional clarity and context regarding its findings.

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  • Comments to DOE on Supplemental Environmental Analysis for Alaska LNG Project

    After the Department of Energy published a supplemental environmental impact statement claiming that exporting liquefied natural gas from a proposed Alaska terminal would decrease greenhouse gas emissions, we submitted comments challenging the Department’s methodology and assumptions. In particular, our comment letter explains that the Department’s analysis unreasonably assumes that the Project would merely displace existing exports from Gulf Coast facilities, and thus overlooks the inevitable economic reality that the Project will increase total natural gas supply and consumption. As our comment letter explains, courts have rejected this “perfect substitution” assumption in related contexts. Moreover, our letter explains that the Department’s lifecycle analysis insufficiently considers the choice of destination countries and is inconsistent with the agency’s analysis of economic impacts.

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  • Amicus Brief in Support of Upholding PJM’s Focused Minimum Offer Price Rule

    Last July, PJM Interconnection (the electricity grid operator for 13 states and the District of Columbia) submitted revisions to its Minimum Offer Price Rule (MOPR) for its capacity market to the Federal Energy Regulatory Commission (FERC) for approval. The new rule (the “Focused MOPR”) would remove an artificial barrier to market entry for resources that receive such externality payments under state climate and clean energy policies. Policy Integrity filed an amicus brief in support of FERC and PJM’s Focused MOPR explaining why the rule is welfare-enhancing and would not threaten reliability.

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  • Joint SC-GHG Comments on Commercial Water Heating Equipment

    Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for commercial water heating equipment. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards, even though the standards would be cost-benefit justified without considering any climate benefits. We also encourage DOE to expand upon its rationale for adopting a global damages valuation and for the range of discount rates it applies to climate effects.

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  • Comments to EPA on its Proposed Asbestos Risk Management Rule

    The Environmental Protection Agency (EPA) has proposed a ban on multiple conditions of use of chrysotile asbestos. The Institute for Policy Integrity and Professor Rachel Rothschild at the University of Michigan Law School submitted comments on the agency’s economic analysis of the proposed rule, identifying numerous ways EPA underestimated the health benefits from reduced cancer cases and lung illnesses and could strengthen the robust scientific, economic and legal basis for EPA’s proposed rule.

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  • Comments on the New York Climate Action Council’s Draft Scoping Plan

    The Climate Leadership and Community Protection Act (CLCPA or the Act) committed New York to an ambitious set of changes across all sectors of the economy. The development of a Scoping Plan, as called for by the Act, will help steer New York's agencies--and legislature--as they initiate those changes. Policy Integrity's comments focus on the Electricity and Gas System Transition chapters of the Draft Scoping Plan. In addition to voicing support for several of the measures listed in that plan, those comments encourage adoption of further measures in a final version of the plan. Those additional measures would support greater coordination of electricity sector stakeholders' decisions and would create a greater degree of certainty about the nature and pace of gas system transition.

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  • Enhancing Consideration of Time Frames in Cost-Benefit Analysis Cover

    Enhancing Consideration of Time Frames in Cost-Benefit Analysis

    Federal agencies frequently provide no justification for their analytical time frame when analyzing the costs and benefits of a policy. This is true even when there are costs and benefits that clearly occur beyond the time frame chosen by the agency. In so doing, agencies risk overlooking key long-term impacts that may justify more stringent regulation.

    This report argues that the Office of Management and Budget (OMB) should take steps to improve how agencies consider analytical time frames in their cost-benefit analyses.

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  • Measuring the Benefits of Power Plant Effluent Regulation Cover

    Measuring the Benefits of Power Plant Effluent Regulation

    The 2020 Steam Electric Reconsideration Rule and Potential Future Methods

    EPA is considering regulations that would clean up the wastewater discharges from power plants, after they were stalled and then rolled back under the Trump administration. As it conducts that analysis, this report urges EPA to provide a robust assessment of the benefits of the regulation, improving on analysis that was conducted in the Obama era. The report reviews the economic framework, literature, and analyses performed to support both the original Obama-era rule and Trump-era revisions, building on Davis Noll and Rothschild (2021), which detailed numerous impacts of the 2020 Rule that EPA neglected to examine. This review highlights key considerations that will strengthen future regulations. 

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  • Comments to EPA on Proposed Transport Rule

    In April 2022, EPA proposed a Federal Implementation Plan (FIP) to reduce interstate transport of ozone pollution using the Clean Air Act's Good Neighbor Provision. We submitted comments supporting the Proposed FIP and recomming that EPA select the regulatory alternative that maximizes net benefits and revise and expand its distributional analysis to better reflect the impacts of the Proposed FIP on vulnerable groups. We also submitted joint comments with a coalition of environmental groups supporting EPA's use of the social cost of greenhouse gases in the Proposed FIP.

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  • Joint Comments to SEC on its Proposal to Enhance and Standardize Climate-Related Disclosures

    Together with the Environmental Defense Fund and Professor Madison Condon of Boston University School of Law, we submitted three sets of comments to the Securities and Exchange Commission (SEC) in support of its Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (Proposed Rule). The Proposed Rule would require publicly traded companies to disclose important information about the extent to which climate change is already affecting their financial performance, their approach to climate-related risk management, their climate-relevant governance structures, and their greenhouse gas emissions, which serve as a proxy for exposure to risk from policy- and market-driven shifts to a clean-energy economy.

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