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Recent Projects

Viewing recent projects in Climate and Energy Policy
  • Comments to FMCSA on Commercial Driver Training Compliance Extension

    The Federal Motor Carrier Safety Administration (FMCSA) proposed to extend the compliance dates of its entry-level commercial driver training program from 2020 to 2022. The program includes space and speed management training that reduces vehicle emissions. FMCSA projects that extending compliance dates would forgo hundreds of thousands of metric tons of greenhouse gas emissions. We submitted joint comments criticizing the agency’s regulatory impact analysis, which vastly underestimates forgone benefits and relies on flawed ‘interim values’ of the social cost of carbon.

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  • Climate Damages of U.S. LNG Exports

    Our resource compiles the greenhouse gas emissions and resulting damages from liquefied natural gas (LNG) export terminals.

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  • Comments to DOE on Changes to Energy Conservation Process Rule

    The Department of Energy (DOE) proposed to change the way it selects energy efficiency standards by excluding certain efficiency levels as not "economically justified" on the grounds of effects to small businesses, market competition, or consumer convenience.The change, however, would allow DOE to irrationally and inconsistently give preference to whichever subset of economic impacts the agency wants to focus on in order to deem standards that otherwise achieve net benefits as instead being not economically justified. We submitted comments explaining how the proposal will not ensure consistent consideration of statutory factors.

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  • Comments to CEQ on the National Environmental Policy Act

    The Council on Environmental Quality (CEQ) proposed changes to the regulations implementing the National Environmental Policy Act (NEPA), a decades-old statute that requires federal agencies to analyze the environmental impact of actions. We submitted comments explaining how the proposed rule runs afoul of the statute, drastically limiting agencies’ abilities to consider various effects and implement NEPA procedures. We also submitted joint comments detailing how the provisions would undermine analysis of climate effects, and encouraging CEQ to promote the use of the social cost of greenhouse gases.

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  • Comments to FERC on the Acadiana and Louisiana XPress Natural Gas Projects

    The Acadiana and Louisiana XPress projects could result in the emission of 31.9 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. We submitted comments encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions and weigh their climate impacts using the social cost of carbon. 

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  • Comments to FERC on the FM100 and Leidy South Natural Gas Projects

    The FM100 and Leidy South projects in Pennsylvania could result in the emission of 17.6 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. 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. 

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  • Comments on the Transportation and Climate Initiative

    The Transportation and Climate Initiative called for public input on a Draft Memorandum of Understanding, which lays out a proposal for a Northeast and Mid-Atlantic regional program to establish a cap on carbon pollution from transportation and invest in further emissions reductions, cleaner fuels, and infrastructure. We submitted comments on the proposal suggesting that TCI adjust its definition of affected fuels, set the emissions cap to better reflect external damages from carbon emissions, implement the banking of allowances carefully, and verify that all offsets are real, permanent, and additional.

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  • Fuel-Economy Standards, Corporate Penalties, and a Very Costly Rollback

    The mistake of setting corporate fuel-economy penalties just a little too low can be magnified by automakers’ decisions to produce millions of cars with worse fuel-economy. And the Trump penalty appears to be way too low to motivate compliance. Here’s a breakdown of the reduced penalty and how it will likely affect cars, consumers, and our climate.

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  • Comments on Connecticut’s Study of the Value of Distributed Energy Resources

    Connecticut’s Department of Energy and Environmental Protection (DEEP) and Public Utilities Regulatory Authority (PURA) are conducting a study to determine how it can best compensate distributed energy resources, like solar panels and residential battery installations, which can provide provide significant value to the grid. DEEP and PURA’s study involves an electric system dispatch simulation model and various DER technology use cases. We submitted comments on the model’s outputs and how they can be improved to better serve the study.

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  • Comments to DOE on Energy Conservation Standards for Refrigerators and Freezers

    The Department of Energy requested input on its analysis of energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers. We submitted comments encouraging DOE to, as it has in the past, monetize the full climate benefits of greenhouse gas emission reductions.

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