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Recent Projects

  • Comments to FERC on LNG Compression Project in New York

    Iroquois Gas Transmission System’s Enhancement by Compression Project would provide a significant increase in natural gas compression and transportation, potentially resulting in over 2.4 million metric tons in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. We submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

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  • Building a Foundation for Sustainable Infrastructure Cover

    Building a Foundation for Sustainable Infrastructure

    Barriers to Infrastructure Development and Federal Policy Solutions

    Most categories of American infrastructure—from transportation and water systems to public school buildings and electricity meters—are in dire need of modernization, and climate change is compounding this challenge. Our report provides policy recommendations at each stage of the infrastructure lifecycle, from project planning and analysis, through financing, construction, and maintenance. We explain how a realigned approach to infrastructure can boost the economy while addressing threats from climate change and prioritizing social equity goals.

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  • Amicus Briefs on Repeal of Fracking Rule

    In 2017, the Bureau of Land Management (BLM) repealed an Obama-era rule that tightens environmental regulations for fracking on public lands. We filed an amicus brief detailing BLM’s irrational analysis of the repeal, which erases the rule’s significant net benefits and flouts longstanding standard practices.

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  • Enhancing the Social Benefits of Regulatory Review Cover

    Enhancing the Social Benefits of Regulatory Review

    Rethinking OIRA for the Next Administration

    In recent years, federal leadership has distorted the practice of regulatory analysis and has eroded the integrity of the government’s regulatory review structure as coordinated by the Office of Information and Regulatory Affairs (OIRA). The result has been a torrent of deregulatory actions that have worked against the best interests of the American people and their health, safety, environment, and financial well-being. Our report details the path forward on regulatory review, which is to first surgically excise recent distortions, and then to reaffirm the best principles and practices from the past, while adding key corrections and enhancements. Implementing the reforms recommended in this report will refocus OIRA on helping agencies once again use regulations to maximize net social welfare.

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  • Comments to BLM on Oil and Gas Leasing in Utah

    Despite being ordered to provide a more thorough analysis of greenhouse gas emissions by a U.S. district court, the Bureau of Land Management (BLM) failed to adequately consider emissions from a number of oil and gas leases in Utah. We submitted comments recommending that BLM use the social cost of carbon to weigh climate impacts and, further, assess the option value of deferring lease sales to improve its land management decisions.

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  • A New Way Forward on Climate Change and Energy Development for Public Lands and Waters Cover

    A New Way Forward on Climate Change and Energy Development for Public Lands and Waters

    The Department of the Interior has yet to develop a comprehensive plan to accurately account for, manage, and mitigate the greenhouse gas emissions that result from the extraction and combustion of fossil fuels from public lands and waters. This document describes immediate and longer-term actions that Interior’s Bureau of Land Management and Bureau of Ocean Energy Management should take to reform public lands management consistent with climate change, conservation, and fiscal reform priorities.

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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 EPA on Airplane Emissions Regulations

    The Environmental Protection Agency (EPA) proposed airplane pollution standards that have no effect on emissions and require no technological improvements. EPA does analyze one scenario in the technical support for the proposal, however, that appears to have modest greenhouse gas emissions reduction effects. But the agency improperly monetizes and weighs those reductions. We submitted joint comments that detail flaws in EPA’s analysis and describe how the agency can correctly apply the social cost of carbon.

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  • Comments to Arizona on Integrated Resource Planning

    The Arizona Corporation Commission regularly requires that load serving entities (LSEs), which supply electricity to ratepayers, file plans with a 15-year time horizon disclosing environmental impacts from different resource mixes and how they will address those impacts. We submitted comments encouraging the Commission to ask that LSEs provide monetized estimates of the damages they expect to result from greenhouse gas emissions using the social cost of carbon.

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  • Comments to FWS on Critical Habitat Designations

    The Fish and Wildlife Service (FWS) proposed amendments to its regulations for designating critical habitat. Several of FWS’s changes are inconsistent with the best practices for weighing the costs and benefits of agency action. We submitted comments explaining how the proposal is flawed in multiple ways and should not be finalized.

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