Recent Projects

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.

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.

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.

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.

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.

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:

Policy Integrity submitted comments to the Environmental Protection Agency (EPA) on the agency’s proposed 2014 standards for the Renewable Fuel Standard (RFS) program. EPA proposes to reduce renewable fuel targets from 2013 levels, due to concerns regarding industry’s ability to produce sufficient quantities of qualifying fuel and consumers’ ability to use the fuel. This backsliding highlights the RFS program’s inability to guarantee steady reductions in greenhouse gas emissions.

On January 10, Policy Integrity, along with New York University’s Guarini Center, submitted comments on Con Edison’s Storm Hardening and Resilience Collaborative Report. The comments urge New York’s Public Service Commission (PSC) to extend the charter of the cost-benefit analysis working group convened as part of the collaborative process surrounding Con Edison’s latest ratemaking proceeding.

The Administrative Conference of the United States (ACUS) Committee on Judicial Review accepted a recommendation made by Policy Integrity on remand without vacatur.

Policy Integrity submitted comments on the draft statement by the Administrative Conference of the United States (ACUS) Committees on Administration and Management, and Regulation, for improving the timeliness, transparency, and effectiveness of the regulatory review process of the Office of Information and Regulatory Affairs (OIRA).