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Viewing recent projects in Public Comments
  • Comments on New Offshore Leasing Plan

    Policy Integrity recently filed public comments on the Bureau of Ocean Energy Management’s (BOEM’s) new offshore leasing proposal, suggesting that the agency update its use of “option value” to improve its valuation of offshore resources.

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  • Energy Conservation Standards - Public Comments

    Policy Integrity has submitted comments to the Department of Energy, encouraging DOE to improve its economic justification for a proposed energy efficiency determination. DOE has determined that energy conservation standards for mercury vapor and metal halide high-­intensity discharge lamps are not “economically justified” as required by statute, even though such standards could save up to 1.6 quadrillion British thermal units of energy. By reducing electricity demand at and pollution from fossil fuel­-fired power plants, such energy savings would generate environmental and health benefits. However, at no point in DOE’s documentation does the agency discuss environmental and health benefits as part of its analysis of “economic justification” and “national impact.”

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  • EPA’s Clean Power Plan - Public Comments

    In Policy Integrity’s recently submitted public comments on the EPA’s Clean Power Plan, we make the case that the EPA’s flexible, cost-minimizing approach to setting performance standards for existing power plants is consistent with over 30 years of EPA Clean Air Act practice, under both Republican and Democratic administrations. While opponents of the Clean Power Plan have argued that the EPA is taking unprecedented and unwarranted steps to regulate carbon dioxide under the Clean Air Act, we show that the plan is deeply rooted in precedent.

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  • Public Comments on Net Metering in Wisconsin

    Wisconsin is one of more than 40 states with a “net metering” law that allows solar-powered households to sell some of the electricity they generate back into the grid for a fixed price. The Wisconsin Electric Power Company and Wisconsin Gas LLC recently proposed changes to their net metering rates, arguing in part that the rates force them to fund additional grid maintenance and modernization without appropriate compensation. However, the current rates also do not account for the climate and public health benefits from distributed solar generation.

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  • Oil Train Safety - Public Comments

    Driven by growth in the production of oil in the U.S. and Canada, there has been a significant increase in rail transportation of crude oil over the past five years, with a corresponding increase in the number of accidents. Many oil trains pass through sensitive environmental habitats and densely populated areas, and even share track with commuter trains in some regions.

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  • Tobacco Products and Consumer Welfare - Public Comments

    Policy Integrity recently submitted public comments to the Food and Drug Administration (FDA) on its proposed rule to deem certain tobacco products, such as electronic cigarettes and cigars, subject to regulation. We believe the FDA may be dramatically understating the benefits from consumer behavior changes due to regulation of new tobacco products.

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  • Offshore Leasing and Option Value - Comments on BOEM’s 2017-2022 Leasing Program

    Policy Integrity recently submitted comments to the Bureau of Ocean Energy Management (BOEM) on its five-year offshore leasing program from 2017-2022. BOEM is charged with stewarding vital and valuable resources for the benefit of the American people. On the one hand, the agency must direct the orderly development of offshore oil and gas deposits; at the same time, the agency must safeguard the ecosystems, cultural assets, and human lives affected by resource extraction decisions, and must preserve competing uses of offshore areas. BOEM thus has a responsibility to ensure the reasonable development of offshore resources so that costs to society are appropriately balanced against the benefits generated. Moreover, BOEM must collect a fair return on any of the American people’s oil and gas reserves that are leased for private development. Finally, the agency must attend to the different effects of offshore development on different regions, ecosystems, and communities.

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  • Public Comments on Methane from Mines to Bureau of Land Management

    On June 30, Policy Integrity submitted comments to the Bureau of Land Management (BLM) regarding the proposed establishment of a program to capture, use, or destroy methane that is released through underground mining operations on federal lands. Coal mining releases large quantities of methane, a potent greenhouse gas, which most mine operators vent directly into the atmosphere. As a result, coal mining is the United States’ fourth largest source of methane emissions, accounting for 10 percent of emissions in 2012.

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  • Joint Public Comments on the Social Cost of Carbon to DOE and HUD

    On May 16, we submitted joint comments on the social cost of carbon to two Department of Energy energy efficiency rules and to another energy efficiency rule proposed jointly by the Department of Housing and Urban Development and the Department of Agriculture. They are substantially similar to those we submitted for EPA’s proposed New Source Performance Standards rule on May 9th. The comments to DOE are available here, and the comments to HUD are available here.

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  • Comments Submitted to EPA on Proposed Emissions Standards for New Power Plants

    Policy Integrity submitted comments to the Environmental Protection Agency on its proposed performance standards for greenhouse gas emissions from new power plants. To help maximize the net benefits of the proposed standards and to ensure their solid legal foundation, Policy Integrity made the following recommendations:

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