Recent Projects

The State of Utah and others filed a lawsuit over EPA’s new Good Neighbor Rule in the U.S. Court of Appeals for the D.C. Circuit. The rule is the latest in a long line of EPA regulations effectuating the requirement that upwind States eliminate emissions that “significantly contribute” to downwind States’ inability to meet certain ambient air quality standards. We filed an amicus brief rebuting multiple arguments against the rule. Our brief explains that addressing the serious and complex spillover effects caused by air pollution was a central justification for the Clean Air Act and EPA’s regulatory impact analysis demonstrates that the rule is economically justified.  

In 2023, the Department of Energy (DOE) issued new energy conservation standards for consumer water heaters and consumer furnaces. In April 2024, a natural gas trade association challenged the standards in the U.S. Court of Appeals for the D.C. Circuit, arguing that the standards are not economically justified. In response, Policy Integrity filed an amicus brief supporting DOE’s economic analyses and explaining how Petitioners’ and certain amici’s arguments overlook DOE’s sound assumptions and the relevant statutory framework.

In April 2024, EPA proposed retaining the secondary national ambient air quality standards (NAAQS) for nitrogen oxides (NOx) and particulate matter (PM) and setting a new annual average standard for sulfur oxides (SOx). Policy Integrity submitted comments arguing that although the Proposed Rule begins to assess the various adverse welfare effects of SOx, NOx, and PM emissions and depositions that different populations may face, EPA should assess, consider, and present more information regarding both distributional impacts and future risks. 

The Federal Emergency Management Agency (FEMA) proposed a rule to modify the standard flood insurance policy under the National Flood Insurance Program by creating a new “Homeowner Flood Form,” which applies specifically to homeowners of single-family homes and owners of buildings with one-to-four units. The proposed amendments reflect sensible steps to simplify the standard flood insurance policy and to provide flexibility in coverage. We have suggested additional improvements to FEMA’s proposal and its underlying analysis.

In May 2024, the Environmental Protection Agency (EPA) issued a request for input on reducing greenhouse gas (GHG) emissions from existing fossil fuel-fired stationary combustion turbines. The Institute for Policy Integrity submitted comments to EPA, providing recommendations on key issues for the agency to consider as it develops new regulations.

On May 13, 2024, FERC issued Order 1920, a landmark rule to improve regional transmission planning and cost allocation processes. The Order could ease the process of expanding electric transmission, helping integrate much more renewable energy to the U.S. grid. We submitted four rounds of comments in this proceeding: at the advanced notice of proposed rulemaking stage, then on the proposal, and then two sets of supplemental comments.  For several key features of the final rule, FERC adopted our recommendations.

On April 30, 2024, Senators Markey, Sanders, Warren, and Whitehouse sent a letter to ISO-NE President and CEO Gordon van Welie urging the independent system operator to improve its governance policies, proactively plan for new transmission, and ensure fair access to markets for clean energy technologies. The letter advocated for several changes that Policy Integrity has pushed in the past, including increasing opportunities for community participation in energy policy decisions and pursuing longer-term, holistic transmission planning. On the latter point, the letter cited our December 2023 report that advocated for more proactive transmission planning on the part of energy decisionmakers.