Recent Projects

Policy Integrity joined other members of the Initiative on Climate Risk and Resilience Law to file comments on the Federal Climate Adaptation Plans recently issued as part of the Biden Administration's Whole-of-Government approach to climate change. Our comments recognize the importance of those plans' issuance and recommend further steps to ensure that federal agencies' approaches to adaptation reflect rigor, transparency, and coherence with respect to other climate-related objectives.

We submitted comments on NHTSA's proposed car standards, recommending ways that the agency could improve its modeling and address inconsistences between its and EPA's analyses. We also submitted joint comments on NHTSA's use of the social cost of carbon, recommending that the agency expand its justification of its discount rates and inclusion of global damages in the SCC.

Policy Integrity submitted joint comments to the Department of Energy’s Supplemental Notice of Proposed Rulemaking for its Manufactured Housing Energy Conservation Standards. Our comments recommend that DOE provide additional rationale for applying the Working Group’s numbers, including by explaining why it is appropriate to focus on a global perspective of climate damages and exclude a 7% discount rate from its analysis of these damages.

The U.S. Postal Service committed to acquiring at least 10% battery electric vehicles (BEVs) over the next decade. We filed comments supporting that decision for monetizing the social cost of the project's marginal greenhouse gas emissions and describing several ways the Postal Service should extend its analysis.

Virginia recently adopted aggressive decarbonization legislation, which recognized that energy storage has an important role to play in decarbonizing the power sector. The Virginia Energy Storage Task Force (VESTF) was convened to help guide the deployment of energy storage resources. Senior Attorney Justin Gundlach served on the task force, and VESTF's final report drew extensively on Policy Integrity's research, including its reports on energy storage policy, valuing DERs, and DERs' emissions reduction potential.

The Federal Energy Regulatory Commission requested responses to a number of questions on the effects of climate change and electric system reliability. In April 2021, we submitted comments highlighting opportunities to improve reliability and resilience by adjusting approaches the Commission and others take to planning, investing in, and operating grid components.

Then FERC, following a technical conference over the summer, requested further comments on a specific series of questions. In September 2021, we submitted joint comments describing process options and resources for conducting climate resilience planning, and emphasized how accounting for climate impacts is relevant to consumer costs.

We submitted comments on the Environmental Protection Agency’s (“EPA”) notice of proposed rulemaking, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. Our comment urged EPA to: select the regulatory alternative that will maximize net social welfare and promote distributional justice; rely on legislative and regulatory history to help justify its aproach to lead time; and improve its modeling to more fully capture benefits of stronger standards.

We also submitted joint comments with a coalition of other environmental groups on EPA's use of the social cost of carbon (SCC) in its proposed regulation, recommending that the agency expand its justification its discount rates and inclusion of global damages in the SCC, and affirm that the SCC is a lower bound of projected climate impacts.

The National Highway Traffic Safety Administration ("NHTSA") sets corporate average fuel economy ("CAFE") standards for light-duty vehicles, and penalizes automobile manufacturers who fail to meet applicable standards. In January 2021, NHTSA issued an Interim Final Rule repealing the inflation-adjusted penalty increase for Model Years 2019-2021, which we commented was untimely and disregarded critical environmental harms. 

In August 2021, NHTSA proposed to rescind the Interim Final Rule. We filed comments supporting the proposal for complying with inflation-adjustment obligations, driving fuel savings, and reducing pollution.

We filed a comment letter with the Federal Energy Regulatory Commission (FERC) regarding their continued failures to meaningfully assess the climate impacts of natural gas infrastructure projects, this time regarding the Alberta Xpress Project DEIS. The project will contribute up to 3.31 million metric tons of carbon dioxide equivalent per year in operational and downstream emissions, and it could cause at least $3.33 billion in climate costs over the twenty-one-year precedent agreement underlying it.