Recent Projects

We recently submitted comments to the EPA regarding their endangerment finding and advance notice of proposed rulemaking on greenhouse gas emissions from aircraft.

Jayni Hein, our policy director, recently participated in the Department of the Interior’s (DOI’s) inaugural listening session on the federal coal program. Hein provided recommendations for modernizing the fiscal terms of federal coal leases at this Washington D.C meeting, held on July 29th. DOI organized the event to solicit input from the public about how the the agency can best carry out its responsibility to ensure that American taxpayers receive a fair return on the coal resources managed by the federal government on their behalf. Secretary of the Interior Sally Jewell attended the listening session.

New York City reached an environmental milestone today as the final deadline passed in a multi-year effort to eliminate the city’s dirtiest residential heating oils. Policy Integrity played a major role in shaping and supporting the NYC Clean Heat program, which has saved hundreds of lives by curbing air pollution.

Today, the Supreme Court ruled that the Environmental Protection Agency (EPA) did not consider costs at the appropriate stage of the regulatory process before crafting the Mercury and Air Toxics Standards. This rule, which regulates toxic emissions from power plants, will now be sent back to the U.S. Court of Appeals for the D.C. Circuit, where the judges will decide how the EPA should proceed.

Today, the U.S. Court of Appeals for the D.C. Circuit dismissed the first challenges to President Obama’s signature climate change initiative—the EPA’s Clean Power Plan. In the ruling, the judges said they would not take the unprecedented step of blocking the EPA’s regulation before a final rule has even been issued.

Our new regulatory report offers guidance on how how the EPA can improve its cost-benefit analysis for a new proposed rule regulating the dispersants used to clean up oil spills and other major pollution events.

Policy Integrity senior advisor Michael Livermore represented the plaintiff in Center for Sustainable Economy v. Jewell, a lawsuit challenging the Bureau of Ocean Energy Management’s (BOEM’s) 2012-2017 leasing plan for the Gulf of Mexico and the Alaskan coast. The Center for Sustainable Economy (CSE) argued that incomplete and flawed economic analysis leads the government to sell resource leases too quickly and too cheaply, potentially costing the American public billions of dollars and leading to high-risk drilling. Today, the U.S. Court of Appeals for the D.C. Circuit ruled against CSE in the case. However, part of the ruling could lead to major changes in how the government values the natural resources it leases.

Policy Integrity’s multi-year effort to make the government account for “option value” in its natural resource leasing decisions has begun to pay off. In its new proposal for offshore oil and gas leasing from 2017-2022, the Department of the Interior’s Bureau of Ocean Energy Management (BOEM) devotes 12 pages to option value and related resource valuation concepts, which will now be considered in leasing decisions. Much of this language closely resembles the arguments Policy Integrity has made to the agency repeatedly since 2009.

Individuals have the right to petition federal agencies to issue, amend, or repeal regulations, but agencies lack a uniform process for handling these petitions. Policy Integrity recently worked with the Administrative Conference of the United States (ACUS), an independent federal agency dedicated to improving the administrative process, to create new guidelines for the petition process. In early December, ACUS adopted new recommendations for federal agencies, based on Policy Integrity’s research and suggestions.

The government’s offshore leasing system fails to account for uncertainties about environmental harms—the system ignores “option value,” a well-established economic technique that quantifies the value of delaying decisions to acquire crucial information. As a result, the current leasing system leads to over-exploitation of natural resources and excessive environmental risk.