Menu
Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in Public Comments
  • Comments to EPA’s Chartered Science Advisory Board

    We submitted four comments in advance of the Environmental Protection Agency’s (EPA) January 2020 meeting of its Chartered Science Advisory Board (SAB).

    Read more

  • Comments to BLM on Proposed Farmington Drilling Projects

    The Bureau of Land Management’s (BLM) Farmington Field Office in New Mexico released an addendum to its environmental assessment for eighty-six drilling applications. The addendum estimates that the projects, in total, would result in more than 483 million metric tons of carbon dioxide-equivalent over the lifetimes of the assessments. BLM’s analysis, however, fails to consider the climate impacts of these emissions, which would amount to more than $25 billion. Our comments ask that BLM provide monetized estimates of these real-world climate impacts using social cost of greenhouse gases metrics.

    Read more

  • Comments to FERC on Putnam Expansion Project

    The Putnam Expansion Project involves the construction and installation of natural gas infrastructure that will result in downstream emissions of approximately 3.26 million metric tons carbon dioxide-equivalent each year. Our comments to the Federal Energy Regulatory Commission (FERC) focus on its environmental assessment of the project, which provides unclear and inadequate analysis of the emissions and their climate impacts. We urge FERC to monetize climate damages by using social cost of greenhouse gas metrics.

    Read more

  • Comments to DOE on Energy Conservation Standards for Fluorescent Lamps

    The Department of Energy proposed to not increase the efficiency of fluorescent lamp ballasts. We submitted comments noting that DOE fails to analyze the forgone emissions reductions of its proposed determination.

    Read more

  • Comments on HHS Changes to Grant Recipient Regulations

    The Department of Health and Human Services (HHS) is proposing to change regulations governing grant recipients, such as foster-care and adoption programs. The rule would allow discrimination on the basis of non-merit factors including sexual orientation or gender identity, likely leading to more denials of service to qualified LGBT individuals and same-sex couples. We submitted comments detailing how HHS fails to provide any analysis of the proposed rule’s costs.

    Read more

  • Comments to FERC on Offshore Wind Transmission

    Due to a significant buildout of offshore wind in the mid-Atlantic as a result of falling costs and state policy commitments, new offshore transmission will be required. However, the market rules for the nation’s largest electricity grid operator, PJM, currently provide no practical path for the development of open-access transmission to connect planned but not-yet-developed offshore wind generation. We submitted comments urging the Federal Energy Regulatory Commission to eliminate barriers to these projects, lowering transmission costs and ensuring just and reasonable rates.

    Read more

  • Comments on Royal Gorge Lease Sale

    The Bureau of Land Management failed to consider the climate impacts of oil and gas leasing activity in Colorado that would produce 317 million tons of carbon dioxide-equivalent over a 30-year period in upstream and downstream emissions. We submitted comments urging the agency to apply the social cost of greenhouse gases in its environmental assessment. 

    Read more

  • Comments on Wyoming Lease Sale

    The Bureau of Land Management failed to estimate the climate impacts of leasing activity that would produce over 5 million tons of carbon dioxide-equivalent in downstream emissions on an annual basis. We submitted comments urging the agency to use the social cost of greenhouse gases in its environmental assessment. 

    Read more

  • Comments to the Department of Labor on Tip Pooling

    The Wage and Hour Division of the Department of Labor (DOL) is proposing to implement new tip regulations under the Fair Labor Standards Act. We submitted comments asking DOL to provide a more detailed explanation of the proposed rule and improve its underlying analysis.

    Read more

  • Comments to EPA on Methane Emissions from Oil and Gas Operations

    The Environmental Protection Agency (EPA) proposed revisions to New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector. We submitted comments focusing on EPA’s flawed legal and economic justifications for the rule.

    Read more