Recent Projects

Together with several environmental nonprofits, we filed comments supporting the Federal Acquisition Regulatory Council's emphasis on climate-sensitive procurement. We endorse using the social cost of greenhouse gases in procurement decisions and suggest rigorous ways for agencies to incorporate those figures into their analyses of different bids and proposals.

We submitted post-technical conference comments to FERC regarding its authority to consider greenhouse gas emissions and to impose mitigation conditions in assessing whether to grant a certificate of public convenience and necessity for interstate natural gas pipelines and other infrastructure projects. Our comments also recommend that the Commission prescribe reasonable default estimates for calculating emissions and monetize climate damages using the social cost of greenhouse gases to assess the project's climate impacts under NEPA and balance them against benefits under the NGA.

We submitted comments to the Department of Health and Human Services (HHS) supporting its proposed repeal of the SUNSET Rule, which retrospectively and prospectively established an "expiration date" for thousands of HHS regulations. We explain why the SUNSET Rule is arbitrary and capricious, echoing our earlier comments, and and propose ways that HHS can strengthen its justification for repealing the rule.

We submitted comments in response to the Federal Transit Administration's (FTA) request for information on updating its Title VI Circular, which lays out nondiscrimination requirements for transit providers who receive funding from the agency. Our comments encourage FTA to require the nondiscriminatory distribution of clean vehicles across transit systems and to create the appropriate reporting requirements that would allow the agency to monitor this.

Policy Integrity submitted comments to the Agency for Healthcare Research and Quality (AHRQ) describing how the agency could integrate climate change and environmental justice considerations into its work.

We submitted joint comments with partners from the Environmental Defense Fund and the Initiative on Climate Risk and Resilience Law supporting the Department of Labor’s (DOL) revision of Trump-era restrictions on ESG investing by retirement plans.

The Bureau of Ocean Energy Management (“BOEM”) recently released an environmental impact statement (“EIS”) for its proposal to lease more than one million acres of submerged land on the Alaska Outer Continental Shelf for oil and gas development. BOEM proposes to take this action despite estimating that it could lead to more than $1.3 billion in climate damages, and despite presenting no estimate of the economic benefits, against which these climate costs might be compared.

We applaud BLM for considering and monetizing climate impacts in their environmental assessments (EAs) for oil and gas lease sales, but recommend that the agency improve its decisionmaking by better incorporating these values into its final determination, considering the informational value of delaying leasing, and conducting more robust environmental justice analyses to inform its decisionmaking.

Our comments recommend that FERC make significant changes to enhance the transmission planning and cost allocation processes -- changes that address barriers to development of regional and interregional transmission that would interconnect and integrate far-flung but low-cost renewable resources. We argue for using a nationally uniform, forward-looking cost-benefit analysis to guide project selection and encourage the Commission to consider prescribing cost allocations that distribute the costs associated with societal benefits and public goods as broadly as possible.

In reply comments to comments submitted by other parties, we clarify that FERC has authority to define the benefits of transmission capacity and to guide the allocation of transmission project costs among beneficiaries.

Policy Integrity encouraged the Department of Homeland Security to supplement its justification for the rule by quantifying and monetizing key unquantified benefits in the RIA, such as improvements in mental health, increased belonging, and hope for the future. The comments also recommended that DHS offer more evidence that the DACA program has no significant effect on legal or illegal immigration and more thoroughly address litigation risk and case-by-case enforcement arguments for rescinding the program.