Menu
Institute for Policy Integrity logo

Recent Projects

  • Comments to CEQ on the Environmental Justice Scorecard

    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.

    Read more

  • Comments to BLM on Coal Management Plans

    In response to a recent court order, the Bureau of Land Management issued a Notice of Intent to amend two resource management plans involving coal leasing: the Buffalo Field Office and Miles City Field Office resource management plans. Our comment letter offers guidance to BLM on how it should consider the climate impacts of different leasing alternatives, as required by the court’s order. The comments discourage the comparison of project emissions to global or national totals, support the use of the social cost of greenhouse gases, and discuss best practices for the proper use of substitution analysis. 

    Read more

  • Comments on Natural Capital Accounting

    In August, the White House Office of Management and Budget published a request for information to help inform the development of government-wide natural capital accounts and standardized environmental-economic statistics. We joined a comment letter with five other organizations supporting this strategy of valuing the nation's capital stocks. The letter explained that management of the nation’s natural capital stocks is vital for our economy, and that comprehensive, consistent, and comparable information on natural capital stocks and flows will improve policy and decision-making. The letter also highlighted the strong theoretical and empirical foundations for valuing natural capital stocks. 

    Read more

  • Comments to EPA on Risk Management Program Revisions

    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.

    Read more

  • Comments on Resource Adequacy to NJ Board of Public Utilities

    The New Jersey Board of Public Utilities (BPU) requested public input on its 2022 Progress Report on New Jersey's Resource Adequacy Alternatives, part of its continuing investigation into achieving New Jersey's resource adequacy and clean energy objectives. We submitted comments identifying specific recommendations for the BPU regarding the implementation of the proposals sets forth in the Progress Report. Among other recommendations, we encouraged the BPU to continue exploring the possibility of indexing renewable energy credits and clean energy attributes to the emissions intensity of displaced generation, identified various challenges associated with its proposal to introduce a market for clean capacity credits, and encouraged the BPU to carefully consider the preemption risk associated with its clean capacity credits market proposal.

    Read more

  • The Role of Information in Distributed Energy Resource Deployment and Policy Cover

    The Role of Information in Distributed Energy Resource Deployment and Policy

    While appropriate compensation for DERs has received considerable attention in DER policy discussions, one important dimension has received less attention: informational gaps and asymmetries. In particular, key information about distribution networks, energy consumption, and marginal emission rates is often either entirely lacking or readily available only to some parties. Such information disparities can impede effective policymaking. To overcome the inefficiencies information asymmetry creates, regulators must carefully tailor disclosure mandates and incentives for utilities, as these actors often have little incentive to go beyond the letter of the law in data disclosure.

    Read more

  • Comments to BLM on Draft SEIS for Willow Master Development Plan

    In 2020, the Bureau of Land Management approved an extraction plan known as the Willow Master Development Plan, which would authorize oil giant ConocoPhillips to drill in Alaska’s North Slope for 30 years. But a federal court blocked the Plan from going into effect because BLM failed to account for several important environmental considerations, and in June, BLM released a draft supplemental environmental impact statement that improves upon the agency’s analysis and now finds that the Project will cause billions upon billions of dollars in climate damage. We submitted comments recognizing the significance of those climate damages and arguing that BLM continues to undervalue climate costs while overvaluing economic benefits. In October 2022, we filed an additional comment letter presenting our original economic modeling that further evinces the flaws in BLM's substitution analysis.

    Read more

  • Supplemental Comments Addressing Impact of West Virginia v. EPA on FERC’s Proposed Policy Statements for Natural Gas Infrastructure

    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.

    Read more

  • Comments to DOE on Grid Resilience and Innovation Partnerships Program

    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.

    Read more

  • Joint SC-GHG Comments on DOE Standards for Consumer Furnaces

    Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for consumer furnaces. 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.

    Read more