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Recent Projects

  • Comments to FERC on NERA Net Metering Petition

    The New England Ratepayers Association (NERA) recently petitioned the Federal Energy Regulatory Commission (FERC) to effectively overturn net metering policies nationwide. While FERC has previously and definitively answered the jurisdictional question concerning net metering, NERA asserts without evidence that controversy persists. We submitted comments describing the flaws of NERA’s argument and urging FERC to reject the petition.

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  • Comments to HHS on Blood Donation Policies

    The Department of Health and Human Services (HHS) asked for public input on a forthcoming report to Congress regarding strategies for ensuring an adequate blood supply during public health emergencies. Our comments recommended that the report endorse elimination of the Food and Drug Administration’s deferral policy for donations from men who have sex with men. The policy, which bars gay and bisexual men from donating blood for three months from the date of their last sexual contact, relies on outdated science regarding HIV transmission risk, stigmatizes gay and bisexual men, and increases the likelihood of blood shortages.

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  • Amicus Brief in Rio Grande LNG Case

    If constructed, the Rio Grande liquefied natural gas terminal and pipeline would be responsible for greenhouse gas emissions resulting in billions of dollars in climate damages. The Federal Energy Regulatory Commission’s (FERC) analysis estimates the quantity of the project’s emissions but does not analyze the context, intensity, or significance of the incremental climate damages they will cause. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to monetize the project’s climate damages using Social Cost of Carbon estimates is arbitrary.

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  • Comments to Oregon PUC on the Social Cost of Carbon

    Oregon Governor Kate Brown signed an executive order directing state agencies, including the Public Utilities Commission (PUC), to reduce greenhouse gas emissions. We submitted comments encouraging the PUC to use Social Cost of Carbon metrics to monetize the benefits of avoided greenhouse gas emissions.

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  • Comments to EPA Science Advisory Board on Economic Analysis Guidelines

    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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  • Comments to Colorado PUC on Valuing Distributed Energy Resources

    The Colorado Public Utilities Commission (PUC) is exploring options for valuing distributed energy resources (DERs) in various contexts, including infrastructure planning, performance-based ratemaking, and others. We submitted comments identifying metrics that capture the value of DERs and suggesting how the PUC can employ those metrics to maximize benefits to the grid and society.

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  • Statement on Racial Justice

    The Institute for Policy Integrity, along with the NYU School of Law, denounces racism in all its forms. We wish to acknowledge the pain and anger being expressed in protests around the country. The murders of George Floyd, Breonna Taylor, Ahmaud Arbery, Tony McDade and countless others have again highlighted the pervasiveness of violence against Black Americans, especially by police, and the deeply ingrained inequality that exists in this country.

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  • Shortchanged: How the Trump Administration's Rollback of the Clean Car Standards Deprives Consumers of Fuel Savings Cover

    Shortchanged: How the Trump Administration’s Rollback of the Clean Car Standards Deprives Consumers of Fuel Savings

    The Trump administration recently replaced the Obama administration’s strongest climate policy, the Clean Car Standards, with a significantly weaker rule. We explain how EPA and NHTSA, to justify the rollback, rely on an analytical gimmick that contravenes decades of agency practice across administrations as well as the principles of basic economics. 

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  • Comments to Rhode Island on Carbon Pricing Study

    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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  • What We Lose When They "Save" Cover

    What We Lose When They “Save”

    The Administration’s Misleading Claims About Deregulatory Cost Savings

    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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