Recent Projects

Policy Integrity has filed comments opposing EPA’s proposal to issue a second stay of the compliance deadlines in the Effluent Rule—a rule that regulates toxic metal discharges from power plants. As we explained in our comments to EPA, EPA has no legal authority for the proposed stay. In addition, EPA failed to provide a reasoned explanation for the stay because it ignored the impact that the stay will have on the benefits of the Effluent Rule.

We recently submitted comments to California’s Public Utilities Commission, focused on the economic analysis used in its longer-term energy planning process across utilities. We ask the Commission to exercise caution in coordinating or consolidating this planning with other energy-related proceedings, as different proceedings have different goals and statutory requirements.

We recently submitted comments to the United States Forest Service on a Draft Environmental Impact Statement (EIS) that makes problematic claims about evaluating greenhouse gas emissions. In the Pine Mountain Late-Successional Reserve Habitat Protection and Enhancement Project Draft EIS, the Forest Service gives three main reasons for not quantifying—or monetizing the effects of—greenhouse gas emissions from the proposed action. First, the Service claims that “project level emissions alone are not sufficient to cause climate change.” Second, the Service claims that the “large majority of Forest Service projects” are too “small” for it to be “presently possible to conduct quantitative analysis of actual climate change effects.” Finally, the Service questions whether “such disclosure would provide a practical or meaningful effects analysis for project decisions.” We explain why each of these reasons is wrong according to economic principles, the requirements of the National Environmental Policy Act, and the Service’s own guidance regarding climate change.

California’s state government is moving forward on electricity and climate policy, likely setting a blueprint for future state and federal action. We submitted comments to the California Public Utilities Commission (CPUC) on factual disputes flagged by stakeholders, related to how utilities will use cost-benefit analysis in decisionmaking. We encouraged staff at CPUC to use the Social Cost of Carbon for its interim greenhouse gas adder, use a 3% discount rate for future damages, include other environmental externalities like air pollution in its analysis, and continue considering societal costs to ensure that the benefits justify the costs of a proposed policy.

We recently submitted comments on the Environmental Protection Agency’s proposal to delay the effective date of EPA’s amendments to the Risk Management Program for twenty more months and to put off the compliance deadlines indefinitely. The original rule was issued under section 112®(7)(A) of the Clean Air Act and updated chemical accident prevention rules at manufacturing plants, after a fatal explosion at a fertilizer plant in West Texas.

We recently submitted comments to the Environmental Protection Agency (“EPA”) regarding its obligation to evaluate existing regulations and identify some for repeal, replacement, or modification under Executive Order 13,777. Our comments are meant to ensure that EPA stays focused on its objective to identify outdated, unnecessary, ineffective, or net-costly regulations for repeal, replacement, or modification and does not prioritize recently promulgated and overwhelmingly cost-benefit justified rules, some of which have been targeted by industry commenters.

We recently submitted two sets of comments to the Office of Natural Resources Revenue (ONRR), making the case against repealing an Obama-era reform that promised to recover millions of dollars in royalties from mining companies—a reform that would have ensured that taxpayers receive fair market value for the use of public lands. Our first set of comments objects to the proposed repeal of the Consolidated Federal Oil & Gas and Federal & Indian Coal Valuation Reform Rule (the “Reform Rule”), while our second set responds to ONRR’s request for comments on whether revisions are necessary to the regulations governing coal, oil, and gas royalties. We previously submitted comments to ONRR on the proposed Reform Rule.

President Trump’s recent executive order on energy disbands the Interagency Working Group on the Social Cost of Carbon (IWG) and withdraws its technical support documents that underpin the IWG’s range of estimates. Instead, the executive order directs federal agencies to continue to monetize the social cost of carbon emissions pursuant to the Office of Management and Budget’s Circular A-4. In our comments, we highlight that the range of estimates from the IWG that agencies have been using, including the number used by the U.S. Army Corps of Engineers in the Draft Environmental Impact Statement, is consistent with Circular A-4 and therefore, consistent with the executive order.

We recently submitted comments to the California Public Utilities Commission on their proposal for an interim greenhouse gas adder. The proposal was for an adder that starts at $0 in 2017 and increases linearly to $250 in 2030. We support the use of a greenhouse gas adder. However, our comments suggest that the Commission instead use an adder based on the Interagency Working Group’s Social Cost of Carbon (“SCC”).

We recently submitted a second set of comments to the California Air Resources Board on its 2017 Climate Change Scoping Plan Update. These comments build on those we submitted in December to ARB on the discussion draft of the scoping plan.