Recent Projects

Policy Integrity's Economics Director Peter Howard joined climate scientists and economic experts in written testimony to the Michigan Public Service Commission (MPSC) about the significance of excessive greenhouse gas emissions that would be generated if Enbridge’s Line 5 tunnel siting permit is approved. Howard explained that “the Proposed Project will generate a present value of $41 billion (in 2020 dollars) or more in net monetized climate costs from 2027 to 2070 as compared to the no-action alternative – in other words, the Proposed Project will generate average annual monetized climate costs of approximately $1 billion each year over this period, plus significant unmonetized climate effects and other unquantified pollution costs to human health and the environment.”

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 Evangeline Pass Expansion Project EIS. Two companies have requested authorization to construct and operate a new pipeline, compressor stations and meter stations in Louisiana and Mississippi, which will be used to transport up to 1,100,000 dekatherms per day to an LNG facility for export.

The North Baja XPress Project would provide a significant increase in natural gas compression and transportation, potentially resulting in 9.5 million metric tons or more in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. In October 2020, we submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

In our August 2021 follow up letter responding to FERC's draft environmental impact statement for the project, we note that the Commission has taken the helpful steps of quantifying direct and downstream emissions, but should still quantify upstream emissions, assess the project's incremental environmental harms, and consider avenues to mitigate emissions.

The East 300 Upgrade Project could result in the emission of over 2.3 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. In March, we submitted comments encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions and weigh its climate impacts using the social cost of carbon. In August, we followed up with a comment letter regarding the Commission's continued failures to meaningfully assess climate impacts in the project's Draft Environmental Impact Statement.

We submitted comments to the Federal Energy Regulatory Commission (FERC) encouraging the agency to accept PJM’s proposed changes to the Minimum Offer Price Rule, which recognizes that generation-based externality payment for clean electricity resources can be welfare-enhancing, and removes the artificial barrier to market entry for resources that receive payments under state climate policies created by the previous rule.

The East Lateral XPress Project could result in the emission of over 3.6 million tons of downstream emissions in carbon-dioxide equivalence per year from the combustion of natural gas. We submitted comments (April 2021) and a follow-up letter (August 2021) encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions, weigh its climate impacts using the social cost of carbon, and consider mitigation measures.

The Federal Energy Regulatory Commission has granted the Marcus Hook Compression Project Limited Notice to Proceed with the first phase of construction activities, which is currently underway. Our recent comments on FERC's draft environmental impact statement for the project recommend that the agency improve its consideration of climate impacts. It can do so by quantifying upstream emissions, assessing the project’s incremental climate harms, and considering avenues to mitigate its greenhouse gas contributions.

Iroquois Gas Transmission System’s Enhancement by Compression Project would provide a significant increase in natural gas compression and transportation, potentially resulting in over 2.4 million metric tons in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. We submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

The Department of Energy (DOE) has issued a notice of intent to prepare an environmental impact statement for energy conservation standards for manufactured housing. We submitted comments urging DOE to use the social cost of greenhouse gas metric whenever it analyzes the effects of greenhouse gas emissions, whether in a regulatory impact analysis, environmental impact statement, or other decisionmaking process.