Recent Projects

In its updated climate damage estimates for greenhouse gas emisisons, the Environmental Protection Agency (EPA) cited Policy Integrity scholarship and analysis dozens of times and adopted some of our key arguments. EPA calculated damages based on averaging three damage functions, one of which was based on a paper by Peter Howard and Thomas Sterner. In setting the scope of damages to examine, the agency also adopted Policy Integrity's argument for the need to consider global damages. EPA similarly relied on our arguments about the need to use lower discount rates when assessing the value of future damages.

We submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for microwave ovens. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards, even though the standards would be cost-benefit justified without considering any climate benefits. We also expand upon DOE's justifications for adopting a global damages valuation and for the range of discount rates it applies to climate effects.

The Department of Energy (DOE) solicited comments on its draft guidance for the Clean Hydrogen Production Standard, a target that will be selected by DOE for the carbon intensity of clean hydrogen. This standard relates to DOE’s implementation of the hydrogen-hub provision of the Bipartisan Infrastructure Law. Policy Integrity and WattTime submitted comments to DOE on how to accurately measure the carbon emissions from using grid electricity to produce hydrogen. In particular, we suggested the use of a marginal-emissions approach instead of an annual-average approach. We also recommended that DOE adhere to rigorous carbon-accounting principles if hydrogen producers want to use market instruments like renewable energy credits or power-purchase agreements to characterize the carbon intensity of hydrogen produced using grid electricity.

In February, the Federal Energy Regulatory Commission proposed two policy statements that called for the consideration of climate impacts in pipeline certificate proceedings. In April, we filed two comments letters on these proposed policy statements, including one letter filed jointly with over two dozen legal scholars rebutting arguments that the Commission lacks authority to consider climate effects in its oversight of natural gas infrastructure under the Natural Gas Act and, relatedly, that the proposed policy statements implicate the major questions doctrine. Today, we submitted supplemental comments rebutting arguments that the Supreme Court’s recent decision on the major questions doctrine in West Virginia v. EPA somehow affects the Commission’s ability to finalize its proposed policy statements.

In July, the Bureau of Ocean Energy Management (BOEM) released its proposed five-year offshore leasing plan, which contemplates scheduling anywhere from zero to eleven lease sales over the coming half-decade. As part of that proposal, BOEM conducts a cost-benefit analysis in which it finds net benefits from offshore leasing, but recognizes uncertainty and specifically calls for comment on this analysis.

In response to this call for comments, Policy Integrity submitted two original reports offering extensive feedback on BOEM’s cost-benefit analysis. As detailed in those reports, BOEM’s analysis severely understates the costs of OCS leasing—particularly the climate costs. Our reports offer original analysis and modeling finding that, properly considered, the climate costs of offshore leasing alone may exceed the total benefits from that leasing.

The Connecticut Public Utilities Regulatory Authority (PURA) issued a straw program design for electric storage. We submitted comments that support PURA's efforts to make energy storage part of its overarching decarbonization agenda and provide feedback. It is important, as we explain, that PURA take into account the potential emissions consequences of energy storage operations in designing its performance-based incentive.