Recent Projects

Policy Integrity submitted comments to the Centers for Medicare & Medicaid Services (CMS) in support of its proposed rule to streamline applications and eligibility determinations for Medicaid, the Children's Health Insurance Program, and the Basic Health Program. Our comments encourage CMS to strengthen the Proposed Rule's cost-benefit analysis by describing the many health and economic benefits that result from increased access to healthcare and engaging in a more robust distributional analysis.

We submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for microwave ovens. 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.

The Department of Energy (DOE) solicited comments on its draft guidance for the Clean Hydrogen Production Standard, a target that will be selected by DOE for the carbon intensity of clean hydrogen. This standard relates to DOE’s implementation of the hydrogen-hub provision of the Bipartisan Infrastructure Law. Policy Integrity and WattTime submitted comments to DOE on how to accurately measure the carbon emissions from using grid electricity to produce hydrogen. In particular, we suggested the use of a marginal-emissions approach instead of an annual-average approach. We also recommended that DOE adhere to rigorous carbon-accounting principles if hydrogen producers want to use market instruments like renewable energy credits or power-purchase agreements to characterize the carbon intensity of hydrogen produced using grid electricity.

Following the passage of the Inflation Reduction Act, the Department of Treasury and the Internal Revenue Service issued a series of Requests for Information seeking comments and suggestions on implementing the tax benefits contained in the historic climate law. Building on Policy Integrity's deep expertise in incorporating equity into the rulemaking process, we submitted general comments advising Treasury and IRS to: 

1. coordinate with other federal agencies with experience incorporating environmental justice and equity into their rulemaking process; and
2. conduct robust stakeholder outreach throughout the guidance and rulemaking process, especially in disadvantaged communities.

In addition, Policy Integrity included specific recommendations with respect to the calculation of carbon intensity for hydrogen production based on recent comments to the Department of Energy. 

Policy Integrity submitted comments on White House Council on Environmental Quality's Environmental Justice Scorecard on behalf of the Environmental Justice Health Alliance (EJHA) and Coming Clean. EJHA and Coming Clean are made up of grassroots environmental justice groups, health organizations, environmental groups, community and neighborhood organizations and many more constituencies united in working towards a healthy, just and equitable present and future. The comments were also signed on to by over 20 grassroots organizations from around the country.

In August, the White House Office of Management and Budget published a request for information to help inform the development of government-wide natural capital accounts and standardized environmental-economic statistics. We joined a comment letter with five other organizations supporting this strategy of valuing the nation's capital stocks. The letter explained that management of the nation’s natural capital stocks is vital for our economy, and that comprehensive, consistent, and comparable information on natural capital stocks and flows will improve policy and decision-making. The letter also highlighted the strong theoretical and empirical foundations for valuing natural capital stocks. 

The Institute for Policy Integrity submitted comments to the Environmental Protection Agency (EPA) regarding its proposed revisions to the Risk Management Program (RMP), under Section 112(r) of the Clean Air Act. EPA’s new proposal will better protect communities from chemical accidents that release toxic air pollution. Policy Integrity recommended that EPA further strengthen its regulatory impact analysis, including its consideration of unquantified benefits and the distribution of benefits and costs between fenceline communities and facilities. In particular, EPA should strengthen its breakeven analysis by better considering how risk mitigation measures decrease the magnitude of accidents and avoid the most-costly accidents or catastrophes. EPA should also clarify its new language concerning climate-related hazards and provide complementary guidance to ensure robust consideration of climate-related hazards by RMP facilities.

The New Jersey Board of Public Utilities (BPU) requested public input on its 2022 Progress Report on New Jersey's Resource Adequacy Alternatives, part of its continuing investigation into achieving New Jersey's resource adequacy and clean energy objectives. We submitted comments identifying specific recommendations for the BPU regarding the implementation of the proposals sets forth in the Progress Report. Among other recommendations, we encouraged the BPU to continue exploring the possibility of indexing renewable energy credits and clean energy attributes to the emissions intensity of displaced generation, identified various challenges associated with its proposal to introduce a market for clean capacity credits, and encouraged the BPU to carefully consider the preemption risk associated with its clean capacity credits market proposal.