Recent Projects

We recently submitted comments on New York State’s Reforming the Energy Vision (REV) initiative

We recently submitted two sets of comments to the EPA and National Highway Traffic Safety Administration on their greenhouse gas standards for trucks.

We recently submitted comments to the EPA regarding their endangerment finding and advance notice of proposed rulemaking on greenhouse gas emissions from aircraft.

We recently submitted comments to the District of Columbia Public Service commission (PSC) regarding their investigation of “technologies and policies that can modernize our energy delivery system.”

We recently submitted comments to the New York State Public Service Commission regarding the Reforming the Energy Vision (REV) initiative, which seeks to spur clean energy innovation and improve consumer choice and affordability in New York State. The Commission sought comments on how best to develop a cost-benefit analysis framework to evaluate utility proposals within the REV and related proceedings. Our comments addressed the consideration of externalities and the social cost of carbon in the Commission’s cost-benefit analysis.

Since 1996, there have been at least 285 incidents of child strangulation by window covering cords. The Consumer Product Safety Commission is considering a regulation to address this issue, and we recently submitted public comments on the Commission’s advance notice of proposed rulemaking. We offered a number of suggestions for improving upon the Commission’s preliminary analysis of the costs and benefits of eliminating cords from window coverings. These included recommendations that the Commission consider the prevention of parental grief as an unquantified benefit of regulation and that it perform separate cost-benefit analyses for each major category of covering (e.g., vinyl blinds, wood blinds, roman shades).

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.

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.”

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.

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.