Recent Projects

In August 2024, the U.S. Army Corps of Engineers released a Draft Integrated Material Management Plan and Environmental Impact Statement as part of its Lower Columbia River Channel Maintenance Plan. In the EIS the Corps cited values for the social cost of greenhouse gases (SC-GHG) from the calculator on Policy Integrity’s Cost of Carbon Website. The Corps also citied our Cost of Carbon website when describing the SC-GHG in the Draft EIS.

In response to congressional interest in marine carbon dioxide removal (mCDR) the Congressional Research Service prepared a brief report on the subject. In the document, CRS cited our recent report on expert consensus about carbon dioxide removal to support that claim that “[some stakeholders] may invoke a moral hazard argument against CDR because they prefer policies and actions to reduce GHG emissions prioritized over those aimed at removing emitted GHG from the atmosphere.”

In March 2024, the Securities and Exchange Commission (SEC) finalized its rules on The Enhancement and Standardization of Climate-Related Disclosures for Investors (Rules). The Rules will require public companies in the United States to make certain climate-related disclosures in their registration statements and annual reports, giving investors critical information to better balance risk in their portfolios. Immediately following the Rules’ release, industry actors and a coalition of states filed lawsuits seeking to vacate the Rules. We filed an amicus brief in the Eighth Circuit, supporting these important Rules. Our brief argues that the petitioners’ economic arguments about the Rules’ costs and benefits suffer from fundamental flaws.

On July 29, 2024, the Workshop Facilitator for the Illinois Commerce Commission finalized its Future of Gas Phase 1 Workshops Facilitator Report to the Commission. The final report incorporated several recommendations that Policy Integrity made in comments responding to presentations and draft documents during the course of Phase 1.

Policy Integrity submitted comments to the Department of Treasury and Internal Revenue Service on their proposed rule implementing the Section 45Y Clean Electricity Production Credit and Section 48E Clean Electricity Investment Credit. The comments focus on the treatment of waste methane fuels under these credits, emphasizing the need for accurate emissions accounting and preventing unintended consequences.

Advocates have been trying for decades to engage FERC in a significant course correction: assessing whether interstate gas pipelines serve the public interest, rather than relying on private contracts to assume that it does. Yet FERC has resolutely ignored its Natural Gas Act mandate to protect the public interest, including when it approved the Regional Energy Access pipeline despite substantial evidence showing the project would serve private interests at the public’s expense. In a case where Policy Integrity submitted an amicus brief demonstrating why FERC’s decision ought not receive deference, the D.C. Circuit vacated FERC’s authorization. This was the first time that the courts have done so for a project where there wasn’t blatant affiliate self-dealing.

The Institute for Policy Integrity submitted comments on the Illinois Commerce Commission's (ICC) draft Phase 1 Report from its Future of Gas Workshops, providing recommendations for the ICC to consider as it plans for Phase 2 of the workshops. Our comments aimed to ensure Phase 2 of the workshops thoroughly examines pathways for decarbonizing Illinois' gas system while considering economic, environmental, and equity impacts.

Institute for Policy Integrity submitted joint comments with Columbia Law School's Sabin Center for Climate Change Law on the California Public Utilities Commission's Order Instituting Rulemaking to Update Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems. The joint comments emphasize the importance of a comprehensive approach to climate resilience planning across utility sectors.

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.