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Recent Projects

Viewing recent projects in Public Comments
  • Public Comments

    Comments to DOE on Energy Conservation Standards for Distribution Transformers

    July 30, 2019

    The Department of Energy (DOE) recently asked for input on energy conservation standards for certain electrical grid equipment. We submitted comments encouraging DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.

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  • Public Comments

    Expert Report on Colorado’s Zero Emission Vehicle Program

    July 9, 2019

    Peter Howard and Jason Schwartz provided an expert report on Colorado’s Zero Emission Vehicle program, which will reduce millions of tons of greenhouse gas emissions annually. They demonstrate how the program’s climate benefits can be monetized and how those estimates can provide useful context for decisionmakers and the public.

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  • Public Comments

    Comments to HUD on Housing Assistance Restrictions for Immigrant Families

    July 9, 2019

    The Department of Housing and Urban Development (HUD) recently proposed a rule that would deny housing assistance to some immigrant households. We submitted comments focusing on serious flaws in HUD’s analysis of the rule’s impacts.

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  • Public Comments

    Comments to FERC on Jordan Cove Natural Gas Project

    July 5, 2019

    We submitted joint comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Jordan Cove natural gas exports project in Oregon. FERC failed to provide a meaningful analysis of the pipeline’s climate effects.

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  • Public Comments

    Comments to the Army Corps of Engineers on the Pebble Mine Project

    July 1, 2019

    We submitted joint comments on the Army Corps of Engineers’ environmental assessment of the Pebble Mine Project in southwest Alaska. The Corps quantifies greenhouse gas emissions from the project but fails to provide a monetized estimate of the climate damages those emissions will produce.

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  • Public Comments

    Comments to FDA on Sunscreen Products

    June 27, 2019

    In February, the Food and Drug Administration (FDA) proposed a rule that would strengthen regulations for sunscreen products. We submitted comments explaining how FDA can improve its analysis of the rule’s impacts.

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  • Public Comments

    Comments on BLM Coal Leasing Environmental Assessment

    June 10, 2019

    The Bureau of Land Management (BLM) recently issued an Environmental Assessment (EA) for its decision to lift the Obama administration’s pause on the federal coal leasing program. We submitted comments explaining how the EA provides flawed and incomplete analysis of BLM’s legal authority, alternatives to resuming leasing, and environmental effects.

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  • Public Comments

    EPA Science Advisory Board Input

    June 6, 2019

    As part of EPA’s June 5-6 meeting of the Chartered Science Advisory Board (SAB), we submitted both oral and written input on several issues, including the Clean Water Rule, power-sector emissions of air toxics, vehicle emissions standards, and the Science Transparency Rule.

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  • Public Comments

    Comments to Iowa Utilities Board on Energy Efficiency Program Benefits

    June 5, 2019

    The Iowa Utilities Board is currently reviewing its policies on energy efficiency planning. We submitted comments supporting some of the suggestions made by stakeholders to better gauge the benefits of the energy efficiency programs.

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  • Public Comments

    Additional Comments to EPA and NHTSA on Vehicle Emissions Standards Economic Analysis

    May 31, 2019

    The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) are proposing to weaken key fuel economy and greenhouse gas emissions standards for future vehicle models. In October, we highlighted our concerns with some of the economic analysis supporting the proposal. The Alliance of Automobile Manufacturers submitted comments that included economic analysis supporting the proposed rule prepared by NERA Economic Consulting and Trinity Consultants. In December, we wrote supplemental comments rebutting NERA and Trinity’s analysis, identifying serious flaws and unexplained departures from longstanding practices. NERA recently responded.

    Our latest comments detail how NERA’s response does not address many of the problems we previously discussed. As our comments explain, the analysis relies on unreliable modeling and methodologies, for which NERA still has not provided critical details. NERA also misstates or fails to respond to our points on a number of topics, such as scrappage and fuel savings benefits. We point out the shortcomings in NERA’s response and provide more detail on each of the topics.

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