Recent Projects

The Environmental Protection Agency and National Highway Traffic Safety Administration used several gimmicks and faulty assumptions to skew the analysis of the rollback rule, obscuring just how harmful it is to the American public. We published a series of reports examining several of the flaws.

The Federal Energy Regulatory Commission proposed a policy statement on carbon pricing in organized wholesale electricity markets. We submitted comments encouraging FERC to strengthen its proposal by making specific clarifications. We later submitted reply comments addressing points made by other commenters and providing further guidance on how FERC can improve its final policy statement.

New York State's Department of Environmental Conservation (DEC) has adopted a damage-cost approach to valuing carbon dioxide pollution. We submitted comments on the DEC's draft guidance supporting the policy. Our comments also raise points about the appropriate use of discount rates, calculating damages for other greenhouse gases, inclusion of co-benefits in analysis, and further considerations for a marginal abatement cost approach.

The expansion of the Bull Mountains Mine project in Montana would allow for an increase in coal production likely resulting in more than $9 billion in climate damages. We filed an amicus brief in the U.S. Court of Appeals for the Ninth Circuit criticizing the Office of Surface Mining’s analysis of the project, which fails to monetize climate impacts using the social cost of carbon. We explain that the project’s full economic benefit is, at most, just one-third of its expected climate costs. 

As the presidential transition begins, the Institute for Policy Integrity has outlined recommended policy priorities for the Biden administration on climate, energy, and environmental policy, and related social equity outcomes. It is crucial that the incoming administration undertake aggressive reforms that are grounded in science and economics. In recent months, we published a series of reports highlighting actionable, near- and medium-term policy recommendations in several key areas.

The Bureau of Land Management and the Bureau of Indian Affairs forecast that resource management in New Mexico's Farmington Mancos-Gallup region would produce more than 300 million metric tons of cumulative greenhouse gas emissions under their preferred alternative. Our joint comments explain that the agencies should better evaluate the proposal's climate impacts using the social cost of greenhouse gases. We also submitted comments focused on the agencies' obligation to conduct environmental justice analysis under Executive Order 12,898.