Recent Projects

In 2020, the Bureau of Land Management approved an extraction plan known as the Willow Master Development Plan, which would authorize oil giant ConocoPhillips to drill in Alaska’s North Slope for 30 years. But a federal court blocked the Plan from going into effect, concluding that BLM’s analysis was deficient and failed to account for several important environmental considerations. With BLM now reopening its environmental review, we submitted comments calling on the agency to bolster its assessment of the Plan’s greenhouse gas emissions and economic need. Our comments, jointly filed with six other environmental groups, largely echo arguments from comments that we submitted when BLM was previously reviewing this proposal in 2019.

The Office of the Comptroller of the Currency (OCC) has issued Draft Principles for Climate-Related Financial Risk Management for Large Banks. Along with partner organizations, we submitted comments supporting the OCC's Draft Principles and offering potential next steps for the OCC.

The Environmental Protection Agency and Army Corps of Engineers recently proposed a rule to return to the pre-2015 definition of the term “waters of the United States” under the Clean Water Act. We submitted comments encouraging the agencies to more fully elucidate the benefits from the proposed regulation, as the current economic analysis understates the rule's positive environmental effects.

Policy Integrity submitted comments to the National Oceanic and Atmospheric Administration (NOAA) on its Notice of Intent to Conduct Scoping and To Prepare a Draft Environmental Impact Statement for the Proposed Chumash Heritage National Marine Sanctuary. Our comments describe some of the potential environmental and economic benefits of marine conservation, and suggest potential ways for NOAA to ensure that its environmental impact statement fully evaluates these effects.

In November 2021, EPA proposed standards to regulate methane emissions from new and existing sources in the oil and natural gas sector. Policy Integrity submitted comments supporting the proposed standards, and recommending that EPA strengthen its proposal by regulating additional leaky sources; conducting a distributional analysis of the rule's expected impacts; extending the time frame of its analysis; quantifying co-benefits; and disaggregating costs and benefits to demonstrate that its proposed standards are both individually and cumulatively net beneficial.

We also submitted joint comments with a coalition of other environmental groups on EPA's use of the social cost of greenhouse gases (SC-GHG) in its proposed regulation, recommending that the agency expand its justification of its discount rates and inclusion of global damages in the SC-GHG, and affirm that the SC-GHG is a lower bound of projected climate impacts.

The new Bipartisan Infrastructure Law establishes two funding programs through the Federal Highway Administration (FHWA) to invest in the deployment of electric vehicle (EV) charging infrastructure. In November, FHWA issued a request for information to shape forthcoming guidance for these programs and emphasized its interest in information on how the guidance could incorporate equity considerations. Policy Integrity submitted comments recommending steps that FHWA and applicants to these funding programs can take to rigorously consider the distributional effects of proposed EV charging infrastructure and factor those effects into ultimate grantmaking decisions. Our comments also recommend that FHWA require applicants to promote robust stakeholder engagement while funding proposals are being developed.

Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on it proposed energy efficiency standard for general service lamps (i.e. lightbulbs). Our comments applaud DOE for using the social cost of greenhouse gases (SC-GHGs) in analyzing the proposed rule, but encourage the agency to expand upon its rationale for adopting a global damages valuation and for the range of discount rates it applies to climate effects. We further recommend that DOE disclose the SC-GHG estimates that it applies after 2050.

We filed joint comments to the Department of Labor’s Occupational Safety and Health Administration (“OSHA”) in response to its advance notice of proposed rulemaking Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. We advised that OSHA develop a heat standard that will be robust to climate impacts, provided recommendations on costs and benefits to consider in the economic analysis for the rule, and encouraged OSHA to use other facets of its statutory authority to complement its rulemaking efforts.

We filed a comment letter with the Federal Energy Regulatory Commission regarding its continued failure to meaningfully assess the climate impacts of natural gas infrastructure projects, this time regarding the Wisconsin Access Project EIS. The company has requested authorization to modify its facilities in Wisconsin to increase its firm capacity by over 50,000 dekatherms per day, which could contribute roughly $55 million in annual climate damage costs. 

The Emergency Temporary Standard (ETS), which directs large employers to require COVID-19 vaccines or testing, represents an important step toward reducing the virus in the workplace. While the agency offers numerous compelling justifications for the proposed rule, this comment highlights several additional rationales regarding the legislative and regulatory history of the Occupational Safety and Health (OSH) Act. A blog post on the issue by comment co-authors and NYU Law students Nina Henry and Alex Jonlin is available here.