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Recent Projects

Viewing recent projects in Natural Resources
  • Court Filings

    Amicus Brief in Atlantic Coast Pipeline Case

    April 12, 2019

    If constructed, the Atlantic Coast Pipeline Project would be responsible for greenhouse gas emissions resulting in over $1.3 billion per year of climate damages. The Federal Energy Regulatory Commission’s (FERC) analysis estimates the quantity of the project’s emissions but does not analyze the context, intensity, or significance of the incremental climate damages they will cause. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to monetize the project’s climate damages using Social Cost of Carbon (SCC) estimates is arbitrary.

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  • News

    Court Overturns Repeal of Valuation Rule

    April 12, 2019

    The Institute for Policy Integrity helped contribute to a significant legal victory, as a federal district court in California today overturned the Trump administration’s repeal of the Interior Department’s Valuation Rule. The Valuation Rule sought to ensure that states and the federal government receive the full value of royalties due for oil, gas, and coal extracted from public lands. While the administration has lost numerous court cases related to deregulation, this is the first decision overturning a repeal of a rule. Policy Integrity submitted an amicus brief in the case and comments on the original rule and the repeal efforts.

    In our amicus brief, we argued that the repeal was unreasonable because of the agency’s inaccurate assessment of the repeal’s economic impact. District Judge Saundra Brown Armstrong’s opinion echoed some of the arguments from our brief and cited an academic article on deregulation written by Bethany Davis Noll and Denise Grab.

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  • Reports

    Pipeline Approvals and Greenhouse Gas Emissions

    April 9, 2019

    In light of growing public awareness of the environmental effects of pipeline projects, the Federal Energy Regulatory Commission (FERC) has faced competing pressures regarding how to balance the need for new natural gas pipelines with their environmental consequences. Concerns about greenhouse gas (GHG) emissions and resulting climate change effects have become a flashpoint in the debate. Our report examines the legal context surrounding FERC’s evaluation of the environmental impacts of proposed interstate natural gas pipelines. We look at FERC’s obligations under the Natural Gas Act and the National Environmental Policy Act, as well as potential improvements the agency can make to its analyses to better inform policy makers and the public about the impacts of proposed projects.

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  • Public Comments

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

    March 13, 2019

    The Bureau of Land Management (BLM) recently prepared a Draft Environmental Impact Statement (DEIS) for an oil and gas leasing plan within the Arctic National Wildlife Refuge (ANWR) Coastal Plain. We submitted comments explaining how fossil fuel extraction in ANWR would pose serious threats to a delicate ecosystem and would contribute significantly to climate change. Our criticism of the DEIS focuses on the methodological flaws in BLM’s analysis and their failure to consider viable leasing alternatives.

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  • Public Comments

    Comments to FERC on Adelphia Gateway Pipeline Project

    February 4, 2019

    The Federal Energy Regulatory Commission (FERC) recently released an Environmental Assessment (EA) for the Adelphia Gateway Project. FERC quantifies nearly 90,000 tons per year of direct carbon dioxide-equivalent emissions, but offers no meaningful analysis of the pipeline’s climate impacts. We submitted joint comments urging FERC to better weigh the significance of project’s impacts using the social cost of greenhouse gases methodology.

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  • Public Comments

    Comments to FERC on Annova Natural Gas Project

    February 4, 2019

    In the Federal Energy Regulatory Commission’s (FERC) Environmental Impact Statement (EIS) for the Annova LNG Brownsville Project, the agency quantifies over 350,000 tons per year of direct operational carbon dioxide-equivalent emissions from the proposed natural gas terminal. But FERC fails to provide meaningful analysis of the resulting climate impacts. We submitted joint comments urging FERC to better contextualize the project’s impacts using the social cost of greenhouse gases methodology.

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  • Court Filings

    Amicus Brief on Climate Impacts of the PennEast Pipeline Project

    December 28, 2018

    In January, the Federal Energy Regulatory Commission (FERC) authorized the construction and operation of the PennEast Pipeline Project, a 116-mile natural gas pipeline between Pennsylvania and New Jersey and associated facilities. FERC’s Environmental Impact Statement (EIS) showed that the project will result in an increase in greenhouse gas emissions but did little more than quantify those emissions, failing to fully analyze and consider the climate impacts of the project. We submitted an amicus brief to the U.S. Court of Appeals for the District of Columbia Circuit that demonstrates how FERC could have used the Social Cost of Carbon to analyze the pipeline’s climate impacts.

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  • Public Comments

    Comments to BLM on Resource Management in the Powder River Basin

    December 21, 2018

    The Bureau of Land Management (BLM) is considering amending Resource Management Plans for the Miles City and Buffalo field offices in the Powder River Basin. The agency will prepare an environmental impact statement (EIS) for the proposal. We submitted comments at the scoping phase urging BLM to provide analysis that quantifies the external costs of fossil fuel development in the region and evaluates critical land management alternatives.

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  • Public Comments

    Comments to BLM on Foidel Creek Mine Expansion

    December 21, 2018

    A proposed expansion of the Foidel Creek Mine in Colorado would allow Peabody Energy to recover nearly five million additional tons of federal coal, extending the mine’s life by an additional two years. We submitted joint comments that critique the Bureau of Land Management’s (BLM) environmental assessment of the expansion, which miscalculates downstream emissions and fails to monetize the climate damages those emissions will produce.

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  • Public Comments

    Comments to FERC on Rio Grande Natural Gas Project

    December 3, 2018

    The Federal Energy Regulatory Commission (FERC) prepared a Draft Environmental Impact Statement (DEIS) for the Rio Grande LNG Project. Despite quantifying over 8 million metric tons of carbon dioxide-equivalent emissions per year from operations, FERC does not account for the climate effects of these emissions. We submitted joint comments that offer a detailed rejection of FERC’s arbitrary and misleading rationale for failing to monetize the project’s climate effects. We urge the agency to apply social cost of greenhouse gases estimates.

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