Recent Projects

Complainants in an ongoing proceeding ask that the Federal Energy Regulatory Commission (FERC) make changes to the New York Independent System Operator (NYISO)'s capacity market that would impose offer floors on all capacity market bids by state-supported renewables. We submitted comments showing why the complaint's arguments and evidence fall short of the legal standards required for FERC to make the findings and grant the relief requested.

New York State's Department of Environmental Conservation (DEC) has adopted a damage-cost approach to valuing carbon dioxide pollution. We submitted comments on the DEC's draft guidance supporting the policy. Our comments also raise points about the appropriate use of discount rates, calculating damages for other greenhouse gases, inclusion of co-benefits in analysis, and further considerations for a marginal abatement cost approach.

ONRR has proposed to roll back large portions of the Valuation Rule, after previously failing in court to both suspend the rule and repeal the rule.  We submitted comments explaining that the agency has failed yet again to provide a reasoned explanation for the rollback. 

The expansion of the Bull Mountains Mine project in Montana would allow for an increase in coal production likely resulting in more than $9 billion in climate damages. We filed an amicus brief in the U.S. Court of Appeals for the Ninth Circuit criticizing the Office of Surface Mining’s analysis of the project, which fails to monetize climate impacts using the social cost of carbon. We explain that the project’s full economic benefit is, at most, just one-third of its expected climate costs. 

A proposed oil and gas lease sale in Colorado would offer over 45,000 acres in areas valuable for recreation, wildlife, environmental conservation, and tourism. We submitted comments explaining how the Bureau of Land Management’s (BLM) environmental assessment neglects its duties to manage public lands for multiple uses and consider more limited leasing scenarios.

As the presidential transition begins, the Institute for Policy Integrity has outlined recommended policy priorities for the Biden administration on climate, energy, and environmental policy, and related social equity outcomes. It is crucial that the incoming administration undertake aggressive reforms that are grounded in science and economics. In recent months, we published a series of reports highlighting actionable, near- and medium-term policy recommendations in several key areas.

The Federal Energy Regulatory Commission’s (FERC) environmental assessment for the Iroquois Gas Transmission System’s Enhancement by Compression Project -- which calls for four natural-gas compressor stations in New York -- fails to estimate the project's downstream or upstream greenhouse gas emissions, and falsely suggests that the project may fully substitute for other sources of fossil-fuel energy. We submitted comments calling on FERC to quantify and monetize greenhouse gas emissions, and rebutting the suggestion that the project will not increase total emissions.