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Recent Projects

  • Comments on New York PSC’s Grid Planning Process

    New York's electric utilities have developed a coordinated grid planning process and an updated approach to analyzing the benefits and costs of infrastructure investments. Policy Integrity filed comments urging the Commission to recognize that compliance with the Climate Act in relation to grid planning requires, at the very least, consideration for planning decisions' impacts of global and local pollutants.

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  • Comments to DOE on CP2 LNG’s Export Application

    Policy Integrity filed comments on Venture Global CP2 LNG's application to the Department of Energy (DOE) for authorization to export liquefied natural gas (LNG) to non-free trade agreement nations. We argued that in line with relevant case law, DOE must consider the indirect greenhouse gas emissions associated with the CP2 LNG project in its National Environmental Policy Act (NEPA) review, and weigh the impacts in its Natural Gas Act Section 3 assessment. In doing so, DOE should apply reasonable assumptions to quantify indirect greenhouse gas emissions and better analyze substitution impacts from LNG exports. Furthermore, DOE should refrain from applying its recent NEPA categorical exclusion rule to the CP2 LNG project due to severe legal deficiencies with that rule. Finally, we urge DOE to work with FERC on a single NEPA review for the project because DOE and FERC's Section 3 authorizations are connected actions under NEPA.

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  • Comments to BLM on Supplemental Environmental Impact Statement for Willow Master Development Plan

    In 2020, the Bureau of Land Management approved an extraction plan known as the Willow Master Development Plan, which would authorize oil giant ConocoPhillips to drill in Alaska’s North Slope for 30 years. But a federal court blocked the Plan from going into effect, concluding that BLM’s analysis was deficient and failed to account for several important environmental considerations. With BLM now reopening its environmental review, we submitted comments calling on the agency to bolster its assessment of the Plan’s greenhouse gas emissions and economic need. Our comments, jointly filed with six other environmental groups, largely echo arguments from comments that we submitted when BLM was previously reviewing this proposal in 2019.

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  • Amicus Brief on New Jersey’s Zero-Emissions Credits Program

    In 2018, New Jersey established a Zero-Emissions Credits (ZECs) program, which provides subsidies to the state’s nuclear power plants for reducing carbon emissions in the energy sector. Our amicus brief explains how the Social Cost of Carbon is the best available estimate for valuing harms caused by carbon dioxide emissions. We also argue that the ZECs program should account for the benefits of avoided emissions both inside and outside of New Jersey.

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  • Comments to OCC on Draft Principles for Climate-Related Financial Risk Management for Large Banks

    The Office of the Comptroller of the Currency (OCC) has issued Draft Principles for Climate-Related Financial Risk Management for Large Banks. Along with partner organizations, we submitted comments supporting the OCC's Draft Principles and offering potential next steps for the OCC.

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  • Reforming Pipeline Review Cover

    Reforming Pipeline Review

    Taking a Closer Look at the Need for New Natural Gas Infrastructure

    The Federal Energy Regulatory Commission (FERC) uses a flawed process to evaluate the need for new, long-lasting gas infrastructure such as interstate pipelines, resulting in a certification process that fails to serve the public interest. As FERC begins to re-examine its approval process for new natural gas infrastructure, our report analyzes the Commission’s authority to consider a broader range of factors when deciding whether a proposed project is in the public interest. The report offers four key recommendations for reform.

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  • Comments to EPA and Army Corps of Engineers on Proposed Revised Definition of “Waters of the United States”

    The Environmental Protection Agency and Army Corps of Engineers recently proposed a rule to return to the pre-2015 definition of the term “waters of the United States” under the Clean Water Act. We submitted comments encouraging the agencies to more fully elucidate the benefits from the proposed regulation, as the current economic analysis understates the rule's positive environmental effects.

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  • Comments on Chumash Heritage National Marine Sanctuary

    Policy Integrity submitted comments to the National Oceanic and Atmospheric Administration (NOAA) on its Notice of Intent to Conduct Scoping and To Prepare a Draft Environmental Impact Statement for the Proposed Chumash Heritage National Marine Sanctuary. Our comments describe some of the potential environmental and economic benefits of marine conservation, and suggest potential ways for NOAA to ensure that its environmental impact statement fully evaluates these effects.

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  • Comments to EPA on Oil and Gas Sector Methane Standards

    In November 2021, EPA proposed standards to regulate methane emissions from new and existing sources in the oil and natural gas sector. Policy Integrity submitted comments supporting the proposed standards, and recommending that EPA strengthen its proposal by regulating additional leaky sources; conducting a distributional analysis of the rule's expected impacts; extending the time frame of its analysis; quantifying co-benefits; and disaggregating costs and benefits to demonstrate that its proposed standards are both individually and cumulatively net beneficial.

    We also submitted joint comments with a coalition of other environmental groups on EPA's use of the social cost of greenhouse gases (SC-GHG) in its proposed regulation, recommending that the agency expand its justification of its discount rates and inclusion of global damages in the SC-GHG, and affirm that the SC-GHG is a lower bound of projected climate impacts.

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  • Comments to FHWA on EV Charging Infrastructure

    The new Bipartisan Infrastructure Law establishes two funding programs through the Federal Highway Administration (FHWA) to invest in the deployment of electric vehicle (EV) charging infrastructure. In November, FHWA issued a request for information to shape forthcoming guidance for these programs and emphasized its interest in information on how the guidance could incorporate equity considerations. Policy Integrity submitted comments recommending steps that FHWA and applicants to these funding programs can take to rigorously consider the distributional effects of proposed EV charging infrastructure and factor those effects into ultimate grantmaking decisions. Our comments also recommend that FHWA require applicants to promote robust stakeholder engagement while funding proposals are being developed.

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