Recent Projects

We submitted comments urging DOE to clarify how it will distribute Infrastructure Investment and Jobs Act (IIJA) project funding and to enhance program transparency. We encourage DOE to more specifically detail how it will evaluate applications and to offer a more precise definition of what "community benefits" it hopes to achieve. We also suggest that DOE require project applicants to submit cost-benefit analyses so that the agency can better compare projects when making funding decisions.

Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for consumer furnaces. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards, even though the standards would be cost-benefit justified without considering any climate benefits. We also expand upon DOE's justifications for adopting a global damages valuation and for the range of discount rates it applies to climate effects.

In July, the Bureau of Ocean Energy Management (BOEM) released its proposed five-year offshore leasing plan, which contemplates scheduling anywhere from zero to eleven lease sales over the coming half-decade. As part of that proposal, BOEM conducts a cost-benefit analysis in which it finds net benefits from offshore leasing, but recognizes uncertainty and specifically calls for comment on this analysis.

In response to this call for comments, Policy Integrity submitted two original reports offering extensive feedback on BOEM’s cost-benefit analysis. As detailed in those reports, BOEM’s analysis severely understates the costs of OCS leasing—particularly the climate costs. Our reports offer original analysis and modeling finding that, properly considered, the climate costs of offshore leasing alone may exceed the total benefits from that leasing.

The Connecticut Public Utilities Regulatory Authority (PURA) issued a straw program design for electric storage. We submitted comments that support PURA's efforts to make energy storage part of its overarching decarbonization agenda and provide feedback. It is important, as we explain, that PURA take into account the potential emissions consequences of energy storage operations in designing its performance-based incentive.

President Biden announced his intent to nominate Richard Revesz to serve as Administrator of the Office of Information and Regulatory Affairs within the U.S Office of Management and Budget. Revesz is AnBryce Professor of Law and Dean Emeritus at NYU School of Law, where he directs the Institute for Policy Integrity. He is one of the nation’s leading voices in the fields of environmental and regulatory law and policy. Revesz will take a leave of absence from the Institute for Policy Integrity during this period. Jack Lienke and Burçin Ünel will serve as Interim Co-Executive Directors of the Institute.