Recent Projects

The U.S. Forest Service’s final approval of a coal mine expansion in Colorado continues to ignore climate damages, despite a 2014 ruling by the U.S. District Court of Colorado asking the Forest Service to disclose the effects greenhouse gas emissions from the project in its Environmental Impact Statement. Our objection to the Forest Service’s decision argues that it cannot legally ignore climate costs, which are not difficult to quantify, while also monetizing the economic upside of changing these coal leases. This objection echoes our previous comments to the Forest Service on the West Elk mine expansion.

Energy Secretary Rick Perry’s controversial proposal to subsidize coal and nuclear plants could have terrible consequences for consumers and public health, as our recent comments and op-ed in US News highlight. In September, Perry asked the Federal Energy Regulatory Commission (FERC) to adopt a new rule that would guarantee coal and nuclear plants their full costs plus a profit, so long as they keep 90 days of fuel on site. Perry claims that these “fuel-secure” plants ensure grid reliability and resilience, but neither he nor FERC adequately define these terms or explain why such a measure is justified.

Nevada’s Senate Bill 65, passed in 2017, directs the state’s Public Utilities Commission to prioritize the sources of electricity that provide the greatest economic and environmental benefits, including considering the potential costs of carbon, when reviewing utilities’ resource plans. Our joint comments with Western Resource Advocates and the Environmental Defense Fund offer guidance to the Commission on how to evaluate the potential costs of carbon. Specifically, we recommend that the Commission should require the utilities’ resource plans to use the Social Cost of Carbon as developed by the federal government in 2016 to evaluate the potential costs of carbon associated with different electricity sources. We also submitted joint comments replying to stakeholder feedback, offering specific feedback on how the Commission can modify its regulations to accomplish the intent of the bill.

In December 2016, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that updates civil penalties for car manufacturers that violate fuel economy standards. NHTSA is now reconsidering the rule, claiming it would have a significant negative economic impact. The agency provides no evidence that economic circumstances have changed since the rule’s finalization to make the rule more costly. Our comments argue that the agency should not proceed with the proposed reconsideration, because it inadequately explained why it changed positions. If the agency does continue with the reconsideration, both the Inflation Adjustment Act and economic cost-benefit analysis would justify an update to the penalties rates rather than maintaining the original penalty rate from 1975.

In August, Environmental Protection Agency and National Highway Traffic Safety Administration announced their intentions to reconsider greenhouse gas and fuel economy standards for light-duty vehicles for model years 2022-2025. Our comments show that the employment effects from the standards are likely to be small, and we provide details on the short comings and biases of industry analyses that purport to show large employment effects. In contrast, the comments explain that the standards will help reduce numerous externalities, resulting in large welfare gains for consumers and the creation of valuable environmental benefits.

On behalf of Policy Integrity, Policy Director Jayni Hein recently delivered a statement at the Department of Interior’s Royalty Policy Committee public meeting on October 4, 2017. Her statement included recommendations on how Interior can achieve “fair market value” for taxpayers for the use and development of federal resources, as well as how Interior can fulfil its “multiple use” mandate.

Vehicle fuel economy standards set by the National Highway Traffic and Safety Administration (NHTSA) help reduce greenhouse gas emissions in the United States by making cars more fuel efficient. Our comments on the reconsideration argue that NHTSA should value the social cost of those emissions as robustly as possible, as they have done in the past. We encourage NHTSA to consider the social cost of greenhouse gases in both the rule’s Environmental Impact Statement and Regulatory Impact Analysis, and that it should use estimates considering global damages of climate change using a three percent or lower discount rate.

A recent report criticizing New York’s Clean Energy Standard (“CES”) incorrectly argues that the CO2-reduction benefits from these programs are non-existent. The report claims that the benefits of reducing CO2 emissions with the CES, which are valued using the Social Cost of Carbon (“SCC”), are “effectively zero.” This conclusion and the preceding assertions are incorrect and inconsistent with basic economics. Our response highlights the flaws of the report and explains that New York’s CES in fact generates significant and crucial environmental benefits.