Menu
Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in Natural Resources
  • Comments to BLM on Big Papi Application to Drill

    In the EA, BLM recycles the main Trump-era arguments that agencies used to justify their decision not to apply the social cost of greenhouse gases. In these comments, we draw BLM’s attention the proposed action's significant climate damages, amounting to between $114 million and $161 million over the lifetime of the planned wells.

    Read more

  • Comments to BLM on Coal Leasing Program Review

    In our comment letter, we call on the agency to substantially reform the coal program to adequately account for externalities and protect the public interest.

    Read more

  • Comments to BLM on Oil and Gas Leasing in the Arctic National Wildlife Refuge

    The Bureau of Land Management (BLM) recently issued a notice of intent to complete a Supplemental Environmental Impact Statement (EIS) for an oil and gas leasing plan within the Arctic National Wildlife Refuge (ANWR) Coastal Plain. We submitted comments explaining how BLM’s previous EIS fell short of the agency’s obligation to assess the effects of oil and gas leasing and to consider reasonable alternatives.

    Read more

  • Comments to FERC on Alberta Xpress Project

    We filed a comment letter with the Federal Energy Regulatory Commission (FERC) regarding their continued failures to meaningfully assess the climate impacts of natural gas infrastructure projects, this time regarding the Alberta Xpress Project DEIS. The project will contribute up to 3.31 million metric tons of carbon dioxide equivalent per year in operational and downstream emissions, and it could cause at least $3.33 billion in climate costs over the twenty-one-year precedent agreement underlying it.

    Read more

  • Testimony in Michigan’s Line 5 Case

    Policy Integrity's Economics Director Peter Howard joined climate scientists and economic experts in written testimony to the Michigan Public Service Commission (MPSC) about the significance of excessive greenhouse gas emissions that would be generated if Enbridge’s Line 5 tunnel siting permit is approved. Howard explained that “the Proposed Project will generate a present value of $41 billion (in 2020 dollars) or more in net monetized climate costs from 2027 to 2070 as compared to the no-action alternative – in other words, the Proposed Project will generate average annual monetized climate costs of approximately $1 billion each year over this period, plus significant unmonetized climate effects and other unquantified pollution costs to human health and the environment.”

    Read more

  • Comments to EPA and USACE on Clean Water Protections

    The Environmental Protection Agency (EPA) and Army Corps of Engineers (USACE) have expressed the intention to repeal the Navigable Waters Protection Rule, which removed critical federal protections on many waterways and has been vacated by a federal court for violating the Clean Water Act. In comments filed to the agencies, we welcome the decision to replace the rule but encourage strong justification for reversing course and point to flaws in the economic analysis for the earlier rule that can support the case for replacing it.

    We previously commented on the rule and its flawed economic justification, published a report on its concealed costs, and filed amicus briefs in court cases that challenged it.

    Read more

  • Comments to FERC on the North Baja Xpress Project

    The North Baja XPress Project would provide a significant increase in natural gas compression and transportation, potentially resulting in 9.5 million metric tons or more in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. In October 2020, we submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

    In our August 2021 follow up letter responding to FERC's draft environmental impact statement for the project, we note that the Commission has taken the helpful steps of quantifying direct and downstream emissions, but should still quantify upstream emissions, assess the project's incremental environmental harms, and consider avenues to mitigate emissions.

    Read more

  • Comments to FERC on East 300 Upgrade Project

    The East 300 Upgrade Project could result in the emission of over 2.3 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. In March, 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. In August, we followed up with a comment letter regarding the Commission's continued failures to meaningfully assess climate impacts in the project's Draft Environmental Impact Statement.

    Read more

  • Comments to FERC on the East Lateral XPress Project

    The East Lateral XPress Project could result in the emission of over 3.6 million tons of downstream emissions in carbon-dioxide equivalence per year from the combustion of natural gas. We submitted comments (April 2021) and a follow-up letter (August 2021) encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions, weigh its climate impacts using the social cost of carbon, and consider mitigation measures.

    Read more

  • Comments to ONRR on Its New Proposal to Rescind Trump-Era Valuation Rule Repeal

    In June 2021, the Department of the Interior’s Office of Natural Resource Revenue's (ONRR) proposed a rule rescinding a Trump-era repeal of the Valuation Rule. This rule sought to ensure that states and the federal government receive the full value of royalties due under the law for oil, gas, and coal extracted from public land. We submitted comments supporting ONRR’s proposal to fully rescind the 2020 Rule and encourage ONRR to further elaborate upon its reasons for fully withdrawing the 2020 Rule, in contrast to other alternatives. We lay out several key provisions in the 2020 Rule where ONRR can expand upon its justification for rescinding.

    This comment letter follows a long line of advocacy that we've made opposing the Trump-era rule and supporting the valuation processes that it rescinded.

    Read more