Menu
Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in Public Comments
  • Comments to Arizona on Integrated Resource Planning

    The Arizona Corporation Commission regularly requires that load serving entities (LSEs), which supply electricity to ratepayers, file plans with a 15-year time horizon disclosing environmental impacts from different resource mixes and how they will address those impacts. We submitted comments encouraging the Commission to ask that LSEs provide monetized estimates of the damages they expect to result from greenhouse gas emissions using the social cost of carbon.

    Read more

  • Comments to FWS on Critical Habitat Designations

    The Fish and Wildlife Service (FWS) proposed amendments to its regulations for designating critical habitat. Several of FWS’s changes are inconsistent with the best practices for weighing the costs and benefits of agency action. We submitted comments explaining how the proposal is flawed in multiple ways and should not be finalized.

    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. 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.

    Read more

  • Comments to Department of Labor on Shareholder Proxy Voting Rule

    A rule proposed by the Department of Labor would limit the shareholder rights of Employee Retirement Income Security Act (ERISA) participants. The rule, in particular, would eliminate opportunities for ERISA fiduciaries to vote on Environmental, Social, and Governance (ESG) proposals that have long-term financial benefits for retirements plans. We worked with the Environmental Defense Fund to submit comments detailing the flaws of the Department’s rule.  

    Read more

  • Comments to BLM on December 2020 Lease Sale in Colorado

    A proposed oil and gas lease sale in Colorado would offer over 45,000 acres in areas valuable for recreation, wildlife, environmental conservation, and tourism. We submitted comments explaining how the Bureau of Land Management’s (BLM) environmental assessment neglects its duties to manage public lands for multiple uses and consider more limited leasing scenarios.

    Read more

  • Comments to FERC on PennEast Amendment Project

    The PennEast 2020 Amendment Project, which provides for various additions to the proposed PennEast pipeline, would result in significant greenhouse gas emissions. We submitted comments on the Federal Energy Regulatory Commissions’s draft environmental assessment of the project, which fails to meaningfully assess the impact of emissions using social cost of carbon metrics.  

    Read more

  • Comments to DOE on Energy Storage Systems

    The Department of Energy (DOE) recently requested input on its Energy Storage Grand Challenge, which is a program aimed at expanding the development and proliferation of energy storage systems in the U.S. electric power system. We submitted comments explaining what tools and policies are necessary to ensure that energy storage systems are accurately valued and can participate fully in the market.

    Read more

  • Comments to EPA on Proposed Dust-Lead Pollution Rules

    The Environmental Protection Agency (EPA) proposed revisions to dust-lead post-abatement clearance levels. We submitted comments emphasizing how EPA, itself, concedes that the economic analysis supporting the rule is inaccurate.

    Read more

  • Comments to the New York PSC on Resource Adequacy

    The Brattle Group developed a resource adequacy scenario analysis for the New York Public Service Commission (PSC), which is considering how to best meet its electricity generating capacity and resource adequacy needs. We submitted comments encouraging the PSC to consider several questions that Brattle’s analysis does not examine in depth.

    Read more

  • Comments to New Jersey on Cost Test Straw Proposal

    The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. We submitted comments encouraging BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. We also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal. 

    Read more