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Statement on Racial Justice
The Institute for Policy Integrity, along with the NYU School of Law, denounces racism in all its forms. We wish to acknowledge the pain and anger being expressed in protests around the country. The murders of George Floyd, Breonna Taylor, Ahmaud Arbery, Tony McDade and countless others have again highlighted the pervasiveness of violence against Black Americans, especially by police, and the deeply ingrained inequality that exists in this country.
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Shortchanged: How the Trump Administration’s Rollback of the Clean Car Standards Deprives Consumers of Fuel Savings
The Trump administration recently replaced the Obama administration’s strongest climate policy, the Clean Car Standards, with a significantly weaker rule. We explain how EPA and NHTSA, to justify the rollback, rely on an analytical gimmick that contravenes decades of agency practice across administrations as well as the principles of basic economics.
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Comments to DOE on Energy Conservation Standards for General Service Lamps
The Department of Energy (DOE) requested input on how it should conduct analysis of the efficiency, economic impact, and emissions of general service fluorescent lamps and incandescent reflector lamps. We submitted comments encouraging DOE to monetize the full benefits of emissions reductions using the social cost of greenhouse gases.
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Comments to Rhode Island on Carbon Pricing Study
Rhode Island is undertaking a study to understand what a state carbon pricing scheme would look like and how it would interact with the state’s participation in the Regional Greenhouse Gas Initiative and the Transportation and Climate Initiative. We submitted comments that support the exploration of implementing a multisectoral carbon price and recommend that the state study a scenario that uses the federal Interagency Working Group’s Social Cost of Carbon.
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What We Lose When They “Save”
The Administration’s Misleading Claims About Deregulatory Cost Savings
The Trump administration regularly boasts about the cost savings of rolling back regulations, focusing on industry profits without considering significant negative impacts. This policy brief address and counters the administration's cost savings claims and demonstrates that they should not be taken at face value.
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Carbon Pricing in Wholesale Energy Markets
Conference Brief
Policy Integrity and the Nicholas Institute for Environmental Policy Solutions at Duke University convened a conference on March 3, 2020, to discuss current, and potential future, approaches to carbon pricing in wholesale markets. This brief highlights some of the major points of discussion and suggests open questions for future study.
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Regulating the Energy Transition
FERC and Cost-Benefit Analysis
This article, published in the Columbia Journal of Environmental Law, argues that, FERC’s management of this transition would be significantly enhanced if it embraced cost-benefit analysis—including accounting for important indirect costs and benefits such as the effect on climate change—to guide its decisionmaking. Changing course and adopting cost-benefit analysis will allow FERC to manage the energy transition while maximizing social welfare, enhancing transparency and accountability, and mitigating legal and political risk
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Understanding EPA’s Enforcement and Compliance Policy During the COVID-19 Pandemic
This issue brief summarizes EPA's enforcement and compliance policy in light of COVID-19, describing its significance and clarifying its contours. The policy opens the door to potentially problematic and harmful actions, especially on a short-term basis.
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Comments to New Jersey BPU on Resource Adequacy Alternatives
The New Jersey Bureau of Public Utilities (BPU) requested public input on its investigation of resource adequacy alternatives. We submitted comments encouraging the New Jersey BPU to recognize important uncertainties affecting the proceeding, consider a broad range of costs of pursuing a Fixed Resource Requirement, and explore the possibility of a carbon pricing program in addition to participation in the Regional Greenhouse Gas Initiative.
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Option Value and the Social Cost of Carbon
What Are We Waiting For?
Scientists and economists have long recognized that significant uncertainties and irreversibility characterize climate change. And yet, the social cost of carbon (SCC), the preeminent policy tool to address climate change applied by the U.S. government, does not include the option value (OV) that arises due to these characteristics. We demonstrate a simple methodology for approximating the OV underlying the SCC using the Bachelier formula