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Recent Projects

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  • Public Comments

    Comments to Interior’s Royalty Policy Committee

    June 6, 2018

    Our policy director, Jayni Hein, published a new op-ed in U.S. News & World Report on the Interior Department’s failure to protect the public interest in fossil fuel leasing decisions. In addition, she submitted the op-ed as public comments to Interior’s Royalty Policy Committee and gave verbal remarks at its meeting on June 6, 2018. Hein argues that Interior is required by law to earn “fair market value” for the use and development of public natural resources, and that providing royalty rate reductions and other undue concessions would inappropriately transfer public revenue to fossil fuel industry stakeholders.

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  • Public Comments

    Oral Comments to EPA’s Science Advisory Board

    May 25, 2018

    EPA’s Science Advisory Board provides independent scientific guidance to the Agency. Our oral comments to EPA’s Science Advisory Board encourage the Board to review the science and economics behind EPA’s proposed deregulatory actions. We ask the Board to consider our recent paper on the full value of reducing particulate matter (PM) pollution in evaluating the benefits of reducing PM below the current National Ambient Air Quality Standards. Our comments also ask the Board to review EPA’s manipulation of economics in order to downplay the climate harms of its deregulatory actions. Specifically, we discuss manipulations of the 2016 Interagency Working Group’s Social Cost of Carbon estimates. We argue that EPA’s new “interim” estimate for the Social Cost of Carbon ignores the global nature of climate damage and obscures the devastating effects that climate change will have on future generations, and we strongly encourage review of the methods used to reach this new “interim” estimate.

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  • Court Filings

    Expert Declaration on Using the Social Cost of Carbon in Environmental Assessments

    May 25, 2018

    Fossil fuel development causes significant harm to the environment and human health, and our work continues to push for public disclosure of these harms. Dr. Peter Howard, our economics director, submitted a declaration on the environmental, public health, and social welfare costs of two resource management plans finalized in 2015 by the Bureau of Land Management (BLM) in Montana and Wyoming. Part of a suit against BLM by the Western Organization of Resource Councils, this declaration was presented alongside declarations from other noted climate experts, including Dr. James Hansen. Dr. Howard found that the air pollution and greenhouse gases emitted during the extraction, processing, transportation, and combustion of 11 billion tons of coal and oil and gas from thousands of wells at these two regions will cause more than $802 billion in damages between 2018 and 2028.

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  • Court Filings

    Brief on Department of Education’s Borrower Defense Rule

    May 11, 2018

    Under Secretary Betsy DeVos, the Department of Education has delayed implementation of the Borrower Defense Rule three times. This 2016 regulation was designed to help students who have been defrauded by for-profit educational institutions discharge their federal student loans. In our amicus brief to the U.S. District Court for the District of Columbia, we argue that the delays must be vacated because the Department failed to provide a reasoned explanation for any of them.

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  • Court Filings

    Brief on the Clean Water Rule’s “Applicability Date”

    May 11, 2018

    The Environmental Protection Agency and Army Corp of Engineers were sued for suspending implementation of the Clean Water Rule through the addition of an “applicability date” to the Clean Water Rule. Our brief to the U.S. District Court for the Southern District of New York in that case argues that the court should vacate the Suspension Rule because the agencies improperly ignored the forgone benefits of suspending the Clean Water Rule.

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  • Public Comments

    Comments to NHSTA on Civil Penalties for Violating Fuel Economy Standards

    May 2, 2018

    In December 2016, pursuant to the Inflation Adjustment Act of 2015, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that adjusted civil penalties for car manufacturers that violate fuel economy standards, in order to line them up better with inflation. That rule put the penalties at $14 per tenth of a mile per gallon. NHTSA is now proposing a new rule to lower the penalties from $14 per tenth of a mile per gallon back to the previous rate of $5.50 per tenth of a mile per gallon, claiming that the $14 penalty would have a significant negative economic impact. Our May 2018 comments argue that NHTSA should explain why it is justified in reducing the penalty from $14 to $5.50 and consider the forgone benefits when considering whether the civil penalties will have a “negative economic impact.” Because NHTSA has not provided this explanation, the proposed reduction is arbitrary and capricious.

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  • Policy Briefs

    Analyzing EPA’s Vehicle-Emissions Decisions

    May 1, 2018

    The Environmental Protection Agency sets greenhouse gas emissions standards for cars and light trucks, and it periodically reevaluates these standards to make sure that car manufacturers can comply. In April 2018, EPA withdrew its previous determination that standards for model year 2022–2025 vehicles were appropriate and would improve public welfare, now saying that more recent information suggests that the standards are too stringent. Our policy brief shows that EPA’s claim—that new information indicates that the assumptions underlying the previous determination are unrealistic—is not supported by the evidence. In fact, the opposite is the case. Recent trends in fuel prices, vehicle sales, automaker compliance, and safety all indicate that the existing 2022–2025 standards can be met at low cost while delivering large benefits to consumers and the economy. EPA’s decision to withdraw the standards will instead cause regulatory uncertainty that will hurt the automotive sector while also harming the environment.

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  • Public Comments

    Comments to EPA on Coal Combustion Residuals Rule

    April 30, 2018

    In 2015, the United States Environmental Protection Agency (EPA) established minimum criteria for the safe disposal of coal combustion residuals. At the time, EPA projected that the new rule would yield substantial health and environmental benefits. EPA now proposes to weaken the requirements of the 2015 rule but insists that doing so “will not change risks to human health and the environment” and thus will have no effect on the projected benefits of the 2015 rule. Our comments explain why EPA cannot reasonably assume that its proposed changes will have no effect on the 2015 rule’s projected benefits.

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  • Public Comments

    Comments on Proposed Repeal of the Clean Power Plan

    April 26, 2018

    As the Environmental Protection Agency (EPA) continues its rulemaking to repeal the Clean Power Plan, we submitted two sets of comments that challenge EPA’s legal and economic arguments for undoing this important climate policy.

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  • Academic Articles/Working Papers

    Environmental Standards, Thresholds, and the Next Battleground of Climate Change Regulations

    April 11, 2018

    Regulations to curtail climate change have the additional benefit of reducing air pollution by accelerating the shift away from carbon-intensive and high-polluting energy such as coal. The benefits from reducing just one air pollutant – particulate matter – account for almost half of the quantified benefits of the Obama Administration’s Clean Power Plan. Regulatory opponents have launched an aggressive attack on the use of these benefits to justify climate change regulations. They claim that these benefits are not real, are accounted for in other regulations, or should not be considered because they are indirect benefits. This article, published in the Minnesota Law Review, collects and analyzes for the first time the robust support for valuing particulate matter and other air pollution reduction benefits. Following an examination of the scientific literature, longstanding agency practices under administrations of both major political parties, and judicial precedent, the authors conclude that particulate matter benefits deserve a meaningful role in regulatory cost-benefit analysis.

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