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Recent Projects

  • 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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  • Federal Court Rules Against Flawed, Domestic-Only Consideration of Climate Costs

    The U.S. District Court for the Northern District of California vacated the Bureau of Land Management's repeal of an Obama-era rule that was designed to reduce wasteful venting of methane from natural gas operations on federal lands. The court ruled in part that it was arbitrary for the Trump Administration to have reduced the estimate of the social cost of methane from $1300 per ton down to just $176 per ton by excluding from consideration any climate effect occurring outside U.S. borders. Policy Integrity has worked for years to build the case against the so-called “domestic-only” estimate of climate costs.

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  • Amicus Briefs on Navigable Waters Protection Rule

    In April, the Environmental Protection Agency (EPA) and Army Corps of Engineers published the Navigable Waters Protection Rule, which considerably restricts the waters and wetlands that are federally protected under the Clean Water Act. We filed briefs in the Northern District of California and District of South Carolina focusing on the agencies’ economic analysis, which the agencies use to obscure the rule’s anticipated harms. We later filed in the Tenth Circuit Court of Appeals and the Northern District of New York.

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  • Weakening Our Defenses Cover

    Weakening Our Defenses

    How the Trump Administration’s Deregulatory Push Has Exacerbated the Covid-19 Pandemic

    The failure of the federal government to adequately safeguard the health, environment, and economy of the United States with efficient regulatory protections is not a new phenomenon. For over three years now, the Trump administration has systematically delayed, undermined, and erased key regulations that protect our health, our environment, our workplaces, our living conditions, and our economy. The steady erosion of regulatory safeguards has severely compromised our baseline defenses against Covid-19.

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  • Comments to BLM on September 2020 Lease Sale in Utah

    A proposed oil and gas lease sale in Utah would offer over 100,000 acres located in areas valuable for recreation, wildlife, environmental conservation, cultural use, and tourism. We submitted comments detailing how the Bureau of Land Management’s environmental assessment neglects its duties to manage public lands for multiple use and consider more limited leasing scenarios. BLM also ignores the option value of delaying the leasing decision and, therefore, is unlikely to obtain fair market value for the nominated land parcels.

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  • Wisdom of the Experts Cover

    Wisdom of the Experts

    Using Survey Responses to Address Positive and Normative Uncertainties in Climate-Economic Models

    The social cost of carbon (SCC) and the climate-economic models underlying this prominent US climate policy instrument are heavily affected by modeler opinion and therefore may not reflect the views of most climate economists. To test whether differences exist, we recalibrate key uncertain model parameters using formal expert elicitation: a multi-question online survey of individuals who have published scholarship on the economics of climate change. Read the article, published in Climatic Change.

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