Recent Projects

Following the passage of the Inflation Reduction Act, the Department of Treasury and the Internal Revenue Service issued a series of Requests for Information seeking comments and suggestions on implementing the tax benefits contained in the historic climate law. Building on Policy Integrity's deep expertise in incorporating equity into the rulemaking process, we submitted general comments advising Treasury and IRS to: 

1. coordinate with other federal agencies with experience incorporating environmental justice and equity into their rulemaking process; and
2. conduct robust stakeholder outreach throughout the guidance and rulemaking process, especially in disadvantaged communities.

In addition, Policy Integrity included specific recommendations with respect to the calculation of carbon intensity for hydrogen production based on recent comments to the Department of Energy. 

Policy Integrity submitted comments on White House Council on Environmental Quality's Environmental Justice Scorecard on behalf of the Environmental Justice Health Alliance (EJHA) and Coming Clean. EJHA and Coming Clean are made up of grassroots environmental justice groups, health organizations, environmental groups, community and neighborhood organizations and many more constituencies united in working towards a healthy, just and equitable present and future. The comments were also signed on to by over 20 grassroots organizations from around the country.

The Institute for Policy Integrity submitted comments to the Environmental Protection Agency (EPA) regarding its proposed revisions to the Risk Management Program (RMP), under Section 112(r) of the Clean Air Act. EPA’s new proposal will better protect communities from chemical accidents that release toxic air pollution. Policy Integrity recommended that EPA further strengthen its regulatory impact analysis, including its consideration of unquantified benefits and the distribution of benefits and costs between fenceline communities and facilities. In particular, EPA should strengthen its breakeven analysis by better considering how risk mitigation measures decrease the magnitude of accidents and avoid the most-costly accidents or catastrophes. EPA should also clarify its new language concerning climate-related hazards and provide complementary guidance to ensure robust consideration of climate-related hazards by RMP facilities.

We submitted comments urging DOE to clarify how it will distribute Infrastructure Investment and Jobs Act (IIJA) project funding and to enhance program transparency. We encourage DOE to more specifically detail how it will evaluate applications and to offer a more precise definition of what "community benefits" it hopes to achieve. We also suggest that DOE require project applicants to submit cost-benefit analyses so that the agency can better compare projects when making funding decisions.

The White House Council on Environmental Quality (CEQ) recently released interim guidance on Carbon Capture, Utilization, and Sequestration (CCUS) to assist federal agencies with regulation, permitting, and associated activities. We filed comments urging CEQ to update the guidance document with additional targeted recommendations for agencies on monitoring, reporting and verification (MRV) programs; project prioritization; and other topics.

The new Bipartisan Infrastructure Law establishes two funding programs through the Federal Highway Administration (FHWA) to invest in the deployment of electric vehicle (EV) charging infrastructure. In November, FHWA issued a request for information to shape forthcoming guidance for these programs and emphasized its interest in information on how the guidance could incorporate equity considerations. Policy Integrity submitted comments recommending steps that FHWA and applicants to these funding programs can take to rigorously consider the distributional effects of proposed EV charging infrastructure and factor those effects into ultimate grantmaking decisions. Our comments also recommend that FHWA require applicants to promote robust stakeholder engagement while funding proposals are being developed.

We submitted comments in response to the Federal Transit Administration's (FTA) request for information on updating its Title VI Circular, which lays out nondiscrimination requirements for transit providers who receive funding from the agency. Our comments encourage FTA to require the nondiscriminatory distribution of clean vehicles across transit systems and to create the appropriate reporting requirements that would allow the agency to monitor this.

Policy Integrity submitted comments to the Agency for Healthcare Research and Quality (AHRQ) describing how the agency could integrate climate change and environmental justice considerations into its work.

We submitted comments encouraging the Council on Environmental Quality (“CEQ”) to expand its legal and economic justification for its proposal to restore several key provisions to the regulations implementing the National Environmental Policy Act (“NEPA”) that were revised improperly in 2020. Our comments also suggest regulations and guidance that would promote the public welfare and enhance agency consideration of greenhouse gas emissions, climate risk, and environmental justice.