Recent Projects

In March, the Environmental Protection Agency (EPA) proposed to strengthen its power plant effluent guidelines by tightening discharge requirements for flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate resulting from steam electricity generation. In our comment letter, we offer several recommendations for EPA to strengthen its consideration of regulatory benefits. 

The Federal Energy Regulatory Commission (FERC), the agency responsible for regulating interstate energy infrastructure and markets, is seeking to better incorporate environmental justice into its decision-making. On March 29th, 2023, FERC held its first-ever Environmental Justice Roundtable where Policy Integrity’s Environmental Justice Director, Al Huang, testified and provided suggestions on how the Commission can identify, avoid, and minimize adverse impacts on environmental justice communities. We submitted additional comments to FERC on these issues, as well as on FERC's legal authority to incorporate environmental justice into its permitting decisions.

Following the passage of the Bipartisan Infrastructure Law, the Federal Energy Regulatory Commission (FERC) proposed implementing regulations for its authority to site transmission projects that have been rejected or not acted upon by states. We filed comments advising FERC that, to make these determinations and satisfy FERC's obligations under the National Environmental Policy Act, the Commission must consider how proposed transmission projects would affect emissions from power plants. Our comments further recommend improvements to the proposed rule's environmental justice provisions, which also relate to FERC's obligation to ensure that proposed projects are consistent with the public interest.

In March 2023, the Consumer Product Safety Commission (CPSC) published a Request for Information on Chronic Hazards Associated with Gas Ranges and Proposed Solutions. We submitted comments which highlighted the major findings from our report. We explained how the CPSC could regulate gas ranges and recommened possible futher actions.

We submitted comment letters to the Department of Energy (DOE) on its proposed rules to strengthen energy conservation standards, respectively, for consumer conventional cooking products and external power supplies. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards. We also suggest that DOE apply additional analysis to each rule using draft updated climate-damage valuations that the Environmental Protection Agency released in November 2022.

We submitted recommendations to the New York Public Service Commission regarding New York’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage, a document that analyzes the need to increase New York’s storage target to 6 GW and the barriers to storage deployment, and provides policy recommendations to help the state achieve 6GW of storage deployment by 2030.

In January, the Council on Environmental Quality published interim guidance providing best practices to federal agencies on the consideration of climate change in environmental reviews conducted under the National Environmental Policy Act. The guidance provides helpful direction to agencies on assessing how proposed actions and their alternatives (1) will contribute to climate change through their greenhouse gas emissions; and (2) will potentially be affected or have their environmental consequences exacerbated by climate change impacts. Our comment commends CEQ on its thorough guidance and provides recommendations to strengthen both areas. 

We submitted comment letters to the Department of Energy (DOE) on its proposed rules to strengthen energy conservation standards for general service lamps and distribution transformers. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards. We also suggest that DOE apply additional analysis to each rule using draft updated climate-damage valuations that the Environmental Protection Agency released in November 2022.

We submitted comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for new and renovated federal buildings. Our comments offer support for the agency's choice to apply the social cost of greenhouse gases to estimate the climate effects of the proposed standards. We also suggest that DOE apply additional analysis using draft updated climate-damage valuations that the Environmental Protection Agency recently released.

We submitted comments to the Federal Acquisition Regulatory Council (FAR Council) on ways to strengthen its proposed rule that would require certain categories of federal contractors to disclose their greenhouse gas emissions and climate-related financial risk, and in some cases set science-based targets to reduce their greenhouse gas emissions.