Recent Projects

The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. We submitted comments encouraging BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. We also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal. 

The Environmental Protection Agency (EPA) proposed a rule adjusting the test procedures to calculate greenhouse gas emissions and fuel economy rates for the GHG and CAFE programs and the Fuel Economy and Environment Label upon adoption of Tier 3 certification test fuel. We submitted comments that encourage EPA to finalize the proposal, and explain that EPA would be required to provide a new proposal, rationale, and analysis if it chooses to forgo the GHG emissions test adustment. 

We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.

If constructed, the Tennessee pipeline extension and related projects would be responsible for substantial greenhouse gas emissions. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to quantify the project’s emissions and monetize climate damages using Social Cost of Carbon estimates is arbitrary.

The Department of Labor proposed a rule that would impose limitations on investors’ ability to choose investments in Environmental Social and Governance (ESG) strategies. We worked with the Environmental Defense Fund to submit comments focusing on the proposal’s flaws.

In 2022, New Mexico’s largest utility company will retire the San Juan Generating Station, a coal-burning power plant that has operated since 1973. In light of the decision, the state’s Public Regulatory Commission (PRC) has adopted a plan to replace the plant’s power output with 100 percent renewable energy and battery storage. The plan is a significant victory for the community groups and environmental advocates that have pushed to expedite the clean energy transition, and our efforts helped pave the way for this decision.

The Virginia State Corporation Commission asked for input in advance of developing a rule for energy storage deployment. Our comments note that energy storage deployment can increase emissions from the electricity sector, even if those deployments also facilitate the integration of variable renewable resources. We urge the Commission, under the Virginia Clean Economy Act, to adopt a rule ensuring that energy storage resources are deployed and operated in ways that reduce net emissions.  

The U.S. District Court for the Northern District of California vacated the Bureau of Land Management's repeal of an Obama-era rule that was designed to reduce wasteful venting of methane from natural gas operations on federal lands. The court ruled in part that it was arbitrary for the Trump Administration to have reduced the estimate of the social cost of methane from $1300 per ton down to just $176 per ton by excluding from consideration any climate effect occurring outside U.S. borders. Policy Integrity has worked for years to build the case against the so-called “domestic-only” estimate of climate costs.

A proposed oil and gas lease sale in Utah would offer over 100,000 acres located in areas valuable for recreation, wildlife, environmental conservation, cultural use, and tourism. We submitted comments detailing how the Bureau of Land Management’s environmental assessment neglects its duties to manage public lands for multiple use and consider more limited leasing scenarios. BLM also ignores the option value of delaying the leasing decision and, therefore, is unlikely to obtain fair market value for the nominated land parcels.