Menu
Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in Natural Resources
  • 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.

    Read more

  • 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.

    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

  • 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

  • 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.

    Read more

  • 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.

    Read more

  • The Real Costs of Offshore Oil and Gas Leasing Cover

    The Real Costs of Offshore Oil and Gas Leasing

    A Review of BOEM’s Economic Analysis for Its Proposed Five-Year Program

    In July 2022, the Bureau of Ocean Energy Management (BOEM) released its proposed Outer Continental Shelf oil and gas leasing program for 2023–2028. That plan contemplates holding up to 11 lease sales over the next five years, and conducts an economic analysis concluding that the benefits of those lease sales would exceed the costs. This report provides comprehensive feedback on BOEM’s economic analysis. As the report details, BOEM vastly understates the environmental and social costs of offshore leasing in several key ways.

    Read more

  • The Public Interest Review for LNG-Related Authorizations Cover

    The Public Interest Review for LNG-Related Authorizations

    After a meteoric rise in production over the past decade, the United States has become the largest exporter of liquefied natural gas (LNG) in the world. Yet, the analysis behind LNG terminal and export approvals overlooks climate and environmental justice impacts, despite promises of imminent reform. Policy Integrity’s new report provides a comprehensive look at the Department of Energy’s (DOE) and the Federal Energy Regulatory Commission’s (FERC) past practice in this space and offers recommendations for improving their review of the climate and environmental justice impacts of LNG approvals.

    Read more

  • Comments to DOE on Supplemental Environmental Analysis for Alaska LNG Project

    After the Department of Energy published a supplemental environmental impact statement claiming that exporting liquefied natural gas from a proposed Alaska terminal would decrease greenhouse gas emissions, we submitted comments challenging the Department’s methodology and assumptions. In particular, our comment letter explains that the Department’s analysis unreasonably assumes that the Project would merely displace existing exports from Gulf Coast facilities, and thus overlooks the inevitable economic reality that the Project will increase total natural gas supply and consumption. As our comment letter explains, courts have rejected this “perfect substitution” assumption in related contexts. Moreover, our letter explains that the Department’s lifecycle analysis insufficiently considers the choice of destination countries and is inconsistent with the agency’s analysis of economic impacts.

    Read more

  • Does Unconventional Energy Extraction Generate More Wastewater? A Lifetime Perspective Cover

    Does Unconventional Energy Extraction Generate More Wastewater? A Lifetime Perspective

    Published in Ecological Economics

    The paper analyzes how wastewater generation patterns differ between unconventional wells and conventional wells, accounting for differences in well configurations and local geology. Using the 2008–2016 monthly production data from 50,039 wells, the authors show that unconventional wells generated more wastewater in the first 12 months of production but less cumulative discharge than conventional wells. Unconventional oil wells had a lower wastewater-to-energy ratio throughout their lifetime than their conventional counterparts, whereas no efficiency gap existed among gas wells. These findings call for targeted strategies to balance the short-term disposal burden and the long-term efficiency gains of unconventional energy extraction.

    Read more