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Recent Projects

Viewing recent projects in Climate and Energy Policy
  • Comments to EPA on Proposed Heavy-Duty Vehicle Emission Standards

    In March 2022, EPA proposed standards to regulate emissions of nitrogen oxides and particulate matter from heavy-duty vehicles beginning with Model Year 2027. Policy Integrity submitted comments recommending that EPA strengthen these crucial standards in order to fulfill EPA's statutory duty to set standards "reflecting the greatest degree of emission reduction achievable." We also made a number of recommendations designed to ensure that EPA is properly comparing regulatory alternatives and accounting for the benefits of strong regulation.

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  • Amicus Brief in Fifth Circuit Supporting Reversal of Injunction on the Social Cost of Greenhouse Gases

    In this amicus brief, we explain how the Interagency Working Group based its climate-damage valuations on voluminous and expert science, and that its approach followed regulatory guidance and precedent. In particular, the brief supports the Working Group's selection of discount rates and geographic scope, explaining how those choices followed expert consensus and were consistent with agency treatment of other regulatory impacts.

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  • Comment Letters on FERC’s Proposed Policy Statements for Natural Gas Infrastructure

    In February, the Federal Energy Regulatory Commission released two policy statements that acknowledged the Commission’s role in shaping the nation’s transition to a low-carbon future and called for the consideration of climate impacts in pipeline certificate proceedings. Today, the Institute for Policy Integrity filed two comment letters to these proposed policy statements.

    In one of our comment letters—filed jointly with over two dozen legal scholars from institutes across the country—we rebut arguments from opponents of the policies that the Commission lacks authority to consider climate effects in its oversight of natural gas infrastructure under the Natural Gas Act.

    In our other comment letter, we explain that the policy statements serve as an important step toward ensuring that upstream and downstream emissions are properly considered in line with the Commission’s statutory obligations, but provide several suggestions for improvements.

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  • Comments to FERC on Regional Energy Access Expansion Project DEIS

    Today we submitted comments to FERC on the draft environmental impact statement for Transcontinental Gas Pipe Line Co.'s Regional Energy Access Expansion Project. These comments offer recommendations for improving the Commission's assessment of climate and environmental justice impacts of the project, and its consideration of alternatives.

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  • Ensuring Robust Consideration of Climate Change Under NEPA Cover

    Ensuring Robust Consideration of Climate Change Under NEPA

    Six Priorities for CEQ’s Phase 2 Rulemaking

    In April 2022, the Council on Environmental Quality (CEQ) finalized a limited, “Phase 1” rulemaking to restore several longstanding features of the regulations that guide agency assessments under the National Environmental Policy Act (NEPA) which CEQ had removed in 2020. In that rule, CEQ reaffirmed its intentions to further revise the regulations to better ensure that agencies make decisions that “advance environmental, climate change mitigation and resilience, and environmental justice objectives.” This policy brief outlines six simple regulatory revisions that CEQ should prioritize for its “Phase 2” rulemaking to improve consideration of climate change during environmental review.

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  • Comments to CEQ on Carbon Capture, Utilization, and Sequestration Guidance

    The White House Council on Environmental Quality (CEQ) recently released interim guidance on Carbon Capture, Utilization, and Sequestration (CCUS) to assist federal agencies with regulation, permitting, and associated activities. We filed comments urging CEQ to update the guidance document with additional targeted recommendations for agencies on monitoring, reporting and verification (MRV) programs; project prioritization; and other topics.

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  • Comments on New York PSC’s Grid Planning Process

    New York's electric utilities have developed a coordinated grid planning process and an updated approach to analyzing the benefits and costs of infrastructure investments. Policy Integrity filed comments urging the Commission to recognize that compliance with the Climate Act in relation to grid planning requires, at the very least, consideration for planning decisions' impacts of global and local pollutants.

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  • Amicus Brief on New Jersey’s Zero-Emissions Credits Program

    In 2018, New Jersey established a Zero-Emissions Credits (ZECs) program, which provides subsidies to the state’s nuclear power plants for reducing carbon emissions in the energy sector. Our amicus brief explains how the Social Cost of Carbon is the best available estimate for valuing harms caused by carbon dioxide emissions. We also argue that the ZECs program should account for the benefits of avoided emissions both inside and outside of New Jersey.

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  • Comments to OCC on Draft Principles for Climate-Related Financial Risk Management for Large Banks

    The Office of the Comptroller of the Currency (OCC) has issued Draft Principles for Climate-Related Financial Risk Management for Large Banks. Along with partner organizations, we submitted comments supporting the OCC's Draft Principles and offering potential next steps for the OCC.

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  • Reforming Pipeline Review Cover

    Reforming Pipeline Review

    Taking a Closer Look at the Need for New Natural Gas Infrastructure

    The Federal Energy Regulatory Commission (FERC) uses a flawed process to evaluate the need for new, long-lasting gas infrastructure such as interstate pipelines, resulting in a certification process that fails to serve the public interest. As FERC begins to re-examine its approval process for new natural gas infrastructure, our report analyzes the Commission’s authority to consider a broader range of factors when deciding whether a proposed project is in the public interest. The report offers four key recommendations for reform.

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