Recent Projects

After Winter Storm Uri, the Texas Legislature tasked the Public Utility Commission of Texas with revisiting its standard for system reliability. The Commission responded by proposing a multi-metric reliability standard—one that defines "reliability" not just in terms of the frequency of outages, but also the maximum tolerable duration and magnitude of these events. In our comments, Policy Integrity supported the Commission's overall approach, because multi-metric reliability criteria are an emerging best practice compared to the old one-in-ten approach. We also suggested other ways the Commission could strengthen its proposal.

The Institute for Policy Integrity submitted comments on the Illinois Commerce Commission's (ICC) draft Phase 1 Report from its Future of Gas Workshops, providing recommendations for the ICC to consider as it plans for Phase 2 of the workshops. Our comments aimed to ensure Phase 2 of the workshops thoroughly examines pathways for decarbonizing Illinois' gas system while considering economic, environmental, and equity impacts.

Institute for Policy Integrity submitted joint comments with Columbia Law School's Sabin Center for Climate Change Law on the California Public Utilities Commission's Order Instituting Rulemaking to Update Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems. The joint comments emphasize the importance of a comprehensive approach to climate resilience planning across utility sectors.

In April 2024, EPA proposed retaining the secondary national ambient air quality standards (NAAQS) for nitrogen oxides (NOx) and particulate matter (PM) and setting a new annual average standard for sulfur oxides (SOx). Policy Integrity submitted comments arguing that although the Proposed Rule begins to assess the various adverse welfare effects of SOx, NOx, and PM emissions and depositions that different populations may face, EPA should assess, consider, and present more information regarding both distributional impacts and future risks. 

The Federal Emergency Management Agency (FEMA) proposed a rule to modify the standard flood insurance policy under the National Flood Insurance Program by creating a new “Homeowner Flood Form,” which applies specifically to homeowners of single-family homes and owners of buildings with one-to-four units. The proposed amendments reflect sensible steps to simplify the standard flood insurance policy and to provide flexibility in coverage. We have suggested additional improvements to FEMA’s proposal and its underlying analysis.

In May 2024, the Environmental Protection Agency (EPA) issued a request for input on reducing greenhouse gas (GHG) emissions from existing fossil fuel-fired stationary combustion turbines. The Institute for Policy Integrity submitted comments to EPA, providing recommendations on key issues for the agency to consider as it develops new regulations.

In March 2024, the Department of Energy published a Notice of Intent Regarding Launching a Voluntary Carbon Dioxide Removal Purchasing Challenge. To participate in the Purchasing Challenge, organizations must disclose to DOE several details about each associated carbon dioxide removal (CDR) credit, including the purchaser, supplier, underlying project, and crediting methodology. The Institute for Policy Integrity submitted comments recommending ways DOE could better balance concerns about the disclosure of commercially sensitive information with the benefits of allowing researchers and market actors to access price data.

In March 2024, the Department of Transportation (DOT) proposed a multifaceted regulation that would facilitate greater access to air transportation for passengers with disabilities, particularly those who depend on wheelchairs and other assistive devices. Policy Integrity submitted comments to the agency arguing that, while DOT persuasively shows that the Proposed Rule carries many important benefits, the agency should improve upon its proposal and the accompanying benefit-cost analysis in several ways

In February, a coalition of public-interest organizations filed a petition for rulemaking requesting that the Montana Public Service Commission consider climate change in its regulation of electric and gas utilities. The Petition for Rulemaking calls on the Commission to consider the impacts of climate change in its proceedings using the Environmental Protection Agency’s latest estimates of the social cost of greenhouse gases. In support of the petition, we submitted comments offering a few helpful insights.