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  • Amicus Brief in Case Challenging SEC Climate-Related Financial Disclosure Rules

    In March 2024, the Securities and Exchange Commission (SEC) finalized its rules on The Enhancement and Standardization of Climate-Related Disclosures for Investors (Rules). The Rules will require public companies in the United States to make certain climate-related disclosures in their registration statements and annual reports, giving investors critical information to better balance risk in their portfolios. Immediately following the Rules’ release, industry actors and a coalition of states filed lawsuits seeking to vacate the Rules. We filed an amicus brief in the Eighth Circuit, supporting these important Rules. Our brief argues that the petitioners’ economic arguments about the Rules’ costs and benefits suffer from fundamental flaws.

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  • Policy Integrity Recommendations Incorporated in ICC Future of Gas Phase 1 Facilitator Report

    On July 29, 2024, the Workshop Facilitator for the Illinois Commerce Commission finalized its Future of Gas Phase 1 Workshops Facilitator Report to the Commission. The final report incorporated several recommendations that Policy Integrity made in comments responding to presentations and draft documents during the course of Phase 1.

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  • Comments to Treasury and the IRS on 45Y and 48E Implementation Regulations

    Policy Integrity submitted comments to the Department of Treasury and Internal Revenue Service on their proposed rule implementing the Section 45Y Clean Electricity Production Credit and Section 48E Clean Electricity Investment Credit. The comments focus on the treatment of waste methane fuels under these credits, emphasizing the need for accurate emissions accounting and preventing unintended consequences.

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  • FERC Decision Vacated in Case Where Policy Integrity Submitted a Brief

    Advocates have been trying for decades to engage FERC in a significant course correction: assessing whether interstate gas pipelines serve the public interest, rather than relying on private contracts to assume that it does. Yet FERC has resolutely ignored its Natural Gas Act mandate to protect the public interest, including when it approved the Regional Energy Access pipeline despite substantial evidence showing the project would serve private interests at the public’s expense. In a case where Policy Integrity submitted an amicus brief demonstrating why FERC’s decision ought not receive deference, the D.C. Circuit vacated FERC’s authorization. This was the first time that the courts have done so for a project where there wasn’t blatant affiliate self-dealing.

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  • Consensus on Carbon Dioxide Removal Cover

    Consensus on Carbon Dioxide Removal

    A Large-Sample Expert Elicitation on the Future of CDR

    Many analysts project that large-scale, widespread carbon dioxide removal (CDR) will be necessary to reach net-zero greenhouse gas emissions, and thereby stop exacerbating climate change before United Nations temperature limits are exceeded this century. However, concerns about costs, technological constraints, safety, environmental justice impacts, moral hazard, and other issues contribute to tremendous uncertainty about the future of CDR. Expert elicitation—the process of formally eliciting the views of relevant subject matter experts to gain insight on complex or uncertain topics—can theoretically help clarify consensus on CDR-related issues. We conducted an expert elicitation on issues related to CDR, surveying an interdisciplinary group of 699 researchers who had published at least one article on CDR in a leading academic journal.

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  • Comments to DOE on Draft Goals for Environmental Justice Strategic Plan

    In June, the Department of Energy (DOE) released draft goals for its Environmental Justice Strategic Plan and requested feedback through public comments. Executive Order 14,096 directs each federal agency to create an environmental justice strategic plan that “sets forth the agency’s vision, goals, priority actions, and metrics to address and advance environmental justice.” Our comments suggested that DOE should include objectives under their proposed goals to develop and issue agency-wide guidance on how to consider and analyze environmental justice concerns in their regulatory and policy actions. 

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  • Comments to EPA Science Advisory Board on Draft Peer Review Report on Draft Revised Environmental Justice Technical Guidance

    EPA's Science Advisory Board (SAB) sought comments on its draft peer review report on EPA’s Draft Revised Environmental Justice Technical Guidance (EJTG). This report reviews the methods and procedures described in EPA’s Draft Revised EJTG for evaluating environmental justice concerns in regulatory actions. The Institute for Policy Integrity submitted comments making three key recommendations that the SAB can use to advise EPA.

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  • Comments to the Public Utility Commission of Texas on System Reliability Standard

    After Winter Storm Uri, the Texas Legislature tasked the Public Utility Commission of Texas with revisiting its standard for system reliability. The Commission responded by proposing a multi-metric reliability standard—one that defines "reliability" not just in terms of the frequency of outages, but also the maximum tolerable duration and magnitude of these events. In our comments, Policy Integrity supported the Commission's overall approach, because multi-metric reliability criteria are an emerging best practice compared to the old one-in-ten approach. We also suggested other ways the Commission could strengthen its proposal.

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  • Comments to the Illinois Commerce Commission on Draft Phase 1 Report from Future of Gas Workshops

    The Institute for Policy Integrity submitted comments on the Illinois Commerce Commission's (ICC) draft Phase 1 Report from its Future of Gas Workshops, providing recommendations for the ICC to consider as it plans for Phase 2 of the workshops. Our comments aimed to ensure Phase 2 of the workshops thoroughly examines pathways for decarbonizing Illinois' gas system while considering economic, environmental, and equity impacts.

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  • Joint Comments to the California Public Utilities Commission on Safety, Reliability, and Resilience Rules for Electrical Distribution Systems

    Institute for Policy Integrity submitted joint comments with Columbia Law School's Sabin Center for Climate Change Law on the California Public Utilities Commission's Order Instituting Rulemaking to Update Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems. The joint comments emphasize the importance of a comprehensive approach to climate resilience planning across utility sectors.

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