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Recent Projects

  • Comments to the NY Department of Environmental Conservation and NYSERDA on Proposed Cap-and-Invest Program

    In 2019, New York’s Climate Leadership and Community Protection Act (Climate Act) was passed by the Legislature and signed by the Governor. The Climate Act set economy-wide greenhouse gas emissions limits and established the Climate Action Council. In its Scoping Plan, the Climate Action Council ultimately recommended implementation of a cap-and-invest program to meet the Climate Act’s emissions reduction requirements. In preparation for developing a proposal, DEC and NYSERDA conducted a preliminary stakeholder outreach process consisting of a series of online Stakeholder Feedback Sessions followed by an informal comment opportunity. Policy Integrity filed comments focused on the scope and structure of the stakeholder outreach process. 

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  • Comments to the Michigan Public Service Commission on DTE and Consumers Energy’s Proposal for a Benefit Cost Analysis Test

    In 2022, as part of a multi-year MI Power Grid Initiative initiative focused on maximizing the benefits of the transition to clean, distributed energy resources, the Michigan Public Service Commission (PSC) directed specified Michigan electric utilities to file a proposal for a benefit-cost analysis (BCA) framework for use in evaluating prospective pilot programs.  In February 2023, DTE Electric Company and Consumers Energy filed a BCA proposal, and on June 23, Policy Integrity submitted comments to the PSC on that propsal. Our comments made several recommendations to ensure that the BCA framework would be useful for properly weighting environmental impacts associated with proposed pilots and maximizing net benefits, including that the test ultimately adopted should incorporate Michigan’s decarbonization policy with greater specificity.

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  • Comments to EPA on Proposal to Strengthen the Mercury and Air Toxics Standards

    In April 2023, the Environmental Protection Agency (EPA) proposed to strengthen and update the National Emission Standards for Hazardous Air Pollutants for coal- and oil-fired power plants, also known as the Mercury and Air Toxics Standards (MATS). In this proposal, EPA clearly explained why it revised the technology review conducted in 2020 and made the emissions standards more stringent on the basis of developments in control technologies. In our comments, we recommended improvements to the proposed update and highlighted areas where EPA's analysis succeeded.

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  • Ünel Named to Advisory Council for New York Electric Grid Operator

    The New York Independent System Operator (NYISO) has appointed Policy Integrity’s Executive Director, Dr. Burçin Ünel, to serve on its Environmental Advisory Council. The Council provides NYISO with information, analysis, and expert perspectives on state and federal environmental policies to help it better achieve its mission of maintaining reliability of the bulk electric system and administering competitive wholesale electricity markets. In her role on the Council, Dr. Ünel will use her expertise in utility regulation and energy policy to help NYISO build and maintain New York's “grid of the future.”

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  • Comments to OMB on Draft Update of Circular A-4

    This spring, the Office of Management and Budget (OMB) proposed a comprehensive update to the federal guidance document on best practices for conducting benefit-cost analysis, known as Circular A-4. Jointly with thirteen other nonprofit groups, we submitted comments commending particular aspects of the update and offering suggestions for further improvement.

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  • Joint Comments to EPA on Proposed Heavy-Duty Vehicles Rule

    In April, the Environmental Protection Agency released a proposal to reduce greenhouse gas emissions from heavy-duty vehicles beginning in model year 2027. Jointly with six other organizations, we submitted comments on EPA’s application of the social cost of greenhouse gases in that rule. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards. We also suggest that EPA apply additional analysis to the rule and all alternatives using draft updated climate-damage valuations that EPA released in November 2022.

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  • Comments to the New York Public Service Commission on Medium- and Heavy-Duty Electric Vehicle Charging

    Together with Resources for the Future, we submitted comments to the New York Public Service Commission in response to questions posed by the Commission about addressing barriers to medium- and heavy-duty electric vehicle charging. Our comments focus on the possibility for managed charging to reduce infrastructure needs and on additional considerations to optimize emissions outcomes. Our comments are centered around depot charging and draw on research that examines fleet charging needs in a depot setting.

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  • Comments to EPA on Proposed Rule to Strengthen Power Plant Effluent Guidelines

    In March, the Environmental Protection Agency (EPA) proposed to strengthen its power plant effluent guidelines by tightening discharge requirements for flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate resulting from steam electricity generation. In our comment letter, we offer several recommendations for EPA to strengthen its consideration of regulatory benefits. 

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  • US Benefit-Cost Analysis Requires Revision Cover

    US Benefit-Cost Analysis Requires Revision

    Letter in SCIENCE Supporting Proposed Adjustment to Discount Rates in Circular A-4

    A critical input in cost-benefit analysis is the discount rate, which determines how much impacts in the future are weighted relative to impacts in the present. Federal guidance currently calls on U.S. agencies to apply discount rates of 3% and 7%. But these rates, particularly the 7% rate, substantially devalue impacts that accrue to future generations, thus putting a thumb on the scale against policies that provide long-term benefits such as environmental and public-health regulation. In April, the Office of Management and Budget (OMB) proposed a comprehensive update to that guidance document, known as Circular A-4. Among other revisions, the draft would update the default discount rate used in federal regulatory analysis to 1.7%. In a letter published in Science, leading global experts on discount rates and cost-benefit analysis support the proposed revision.

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  • Letter to Treasury Department on the Use of Carbon Matching for Hydrogen Tax Credits

    Along with seven partners, we submitted a letter to the Department of the Treasury about the best methodology for determining lifecycle greenhouse gas emissions of hydrogen production when calculating the applicable amount of the 45V production tax credit (PTC). The letter had two primary purposes: (1) if local hourly energy matching is adopted as part of 45VPTC implementation, to highlight the critical importance of defining “local” in such a way that avoids increasing carbon emissions, and (2) to advocate for carbon matching as a more cost-effective and scalable alternative compliance pathway that also solves the problem that local hourly energy matching addresses.

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