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  • Best Practices for Energy Substitution Analysis Cover

    Best Practices for Energy Substitution Analysis

    In recent years, numerous federal agencies have made a controversial claim: that projects locking in fossil fuels over the long term will decrease aggregate greenhouse gas emissions, or that their effects on total emissions will be limited. In many of those cases, however, agencies have reached this counter-intuitive conclusion using a flawed consideration of energy substitution. This report identifies some of the recurring problems with agency analysis of energy substitution and offers best practices to apply moving forward.

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  • Amicus Brief in D.C. Circuit Defending BOEM’s Authority to Robustly Consider Climate Impacts in Offshore Leasing

    Earlier this year, a group of environmental organizations successfully challenged an offshore oil-and-gas lease sale held by the Bureau Ocean Energy Management on the basis that BOEM inadequately assessed the impacts on climate change from the combustion of the fossil fuels that the lease sale would facilitate. In its appeal to the D.C. Circuit, the American Petroleum Institute countered that any analytical limitations were harmless because the Outer Continental Shelf Lands Act bars BOEM from considering climate-change impacts when administering leasing policy. Our amicus brief rebuts this argument and defends BOEM’s authority to consider downstream climate impacts in its administration of the offshore leasing program. Our brief explains that the consideration of downstream emissions is consistent with OCSLA’s text, legislative history, regulatory history, and caselaw.

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  • Enacting the  “Polluter Pays” Principle Cover

    Enacting the “Polluter Pays” Principle

    New York’s Climate Change Superfund Act and Its Impact on Gasoline Prices

    This policy brief analyzes how New York State’s recently proposed Climate Change Superfund Act is most likely to affect consumer gasoline prices. The Act would require payments from fossil-fuel companies based on their historical contributions to current greenhouse gas levels in the atmosphere. The payments would be used to build green infrastructure to help the state adapt to climate change. The brief finds that the Act would likely have a negligible impact on current and near-term oil prices, while potentially lowering future energy prices in New York, including for transportation.

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  • Comments on BSEE Well Control Rule

    Policy Integrity submitted comments to the Bureau of Safety and Environmental Enforcement (BSEE), located within the Department of the Interior, in support of its proposed rule to strengthen regulations for well control and blowout preventer systems in the Outer Continental Shelf. This rule aims to reduce the risk of loss-of-well-control events, such as the Deepwater Horizon oil spill, by tightening well operator reporting requirements and equipment standards. Our comments encourage BSEE to strengthen the Proposed Rule's cost-benefit analysis by performing a break-even analysis and quantitatively assessing and/or qualitatively describing the full range of harms that result from well blowouts.

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  • 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. 

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  • 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. 

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  • 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.

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  • 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.

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  • Interior’s Authority to Consider Downstream Emissions from Offshore Leasing Cover

    Interior’s Authority to Consider Downstream Emissions from Offshore Leasing

    In its proposed Outer Continental Shelf oil and gas leasing program for 2023–2028, the Bureau of Ocean Energy Management (BOEM) claims that it cannot consider downstream greenhouse gas emissions when setting leasing policy because of a 2009 D.C. Circuit case, Center for Biological Diversity v. Department of the Interior (CBD). This Policy Brief explains that BOEM misreads CBD, which held only that the Outer Continental Shelf Lands Act (OCSLA) does not require the agency to consider downstream effects. The Policy Brief further explains that neither CBD nor any other case law bars BOEM from considering downstream effects and that consideration of such effects is in fact consistent with the text, legislative history, and regulatory history of OCSLA.

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  • Comments to Bureau of Ocean Energy Management on Proposed Five-Year Offshore Leasing Plan

    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.

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