Recent Projects

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.  

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. 

In March 2024, a set of states and industry groups asked the U.S. Court of Appeals for the District of Columbia Circuit to stay the implementation of EPA’s rule to limit methane emissions from the oil and gas sector. Our Economics Director, Peter Howard, authored an expert declaration defending the agency's development and use of new values for the social cost of methane in the rule.

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.