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Recent Projects

  • Analytical Clarity Cover

    Analytical Clarity

    How Updated Climate-Damage Values and Discount Rates Will Affect Regulatory Analysis

    Recently completed and draft guidance is ushering in updated practices for federal benefit-cost analysis. This policy brief examines the impact of two of the most significant upcoming changes: to the discount rate and the social cost of greenhouse gases.

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  • Transmission Planning for the Energy Transition Cover

    Transmission Planning for the Energy Transition

    Rethinking Modeling Approaches

    This report examines the critical role of modeling details and assumptions that transmission planners frequently ignore. We first provide an overview of the wide array of choices planners have when designing traditional transmission planning models. We then discuss how planners need to rethink these choices to account for the rapidly evolving energy system and the additional uncertainties climate change brings. Finally, we present a modeling case study to show how important these modeling choices could be for transmission outcomes.

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  • The Continued Need for SEC Action on Climate-Related Disclosures Cover

    The Continued Need for SEC Action on Climate-Related Disclosures

    How New California and E.U. Requirements Reinforce the Economic Case for the SEC’s Proposed Rule

    On March 21, 2022, the Securities and Exchange Commission (SEC) proposed a rule that would require SEC registrants (both domestic and foreign) to provide climate-related disclosures in certain SEC filings. Since the release of the SEC Proposal in March 2022, other jurisdictions, including California and the European Union, have adopted climate-related disclosure regimes. Like many federal rules, the SEC Proposal included an assessment of its costs and benefits. This report examines how the California and E.U. disclosure regimes may affect the baseline for that cost-benefit analysis and, consequently, the SEC’s assessment of the incremental costs and benefits of its proposal. Overall, we find that the new disclosure regimes do not undermine the economic case for the SEC Proposal; if anything, they bolster it.

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  • Comments to EPA on the Proposal to Limit Emissions from Reclassified Major Sources of Air Toxics

    In November 2020, EPA finalized a rule withdrawing the “Once-in, Always-in” Policy, under which facilities that are “major sources” of emissions at the first compliance date for the applicable standard must comply permanently with the requirements for a major source. This 2020 Rule allows major sources of toxic air pollution to reclassify as area sources, which are subject to less stringent or no emission control requirements. The 2020 Rule therefore creates the potential for very large increases in toxic air pollution. In September 2023, EPA proposed new safeguards to prevent increased emissions from sources that reclassify and restores federal enforceability requirements for potential to emit limits. We submitted comments on the analysis underlying the proposed new safeguards.

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  • Policy Integrity Work Shapes Long-Overdue Updates to Federal Regulatory Guidance

    On November 9th, the White House finalized its revision of Circular A-4, the primary guidance on how federal agencies should assess the costs and benefits of regulations. This document plays a critical role in federal policymaking, and it had not been updated in two decades. The new guidance represents a major improvement over current practice and incorporates numerous changes that Policy Integrity has long recommended.

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  • Comments to PHMSA on Proposed Pipeline Safety Initiatives

    In September 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed a regulation to improve the safety of certain gas pipelines. The standards include a suite of reforms to help prevent incidents like the catastrophic 2018 gas pipeline explosions in Merrimack Valley, Massachusetts. In a comment letter, we explain that, while the Proposed Rule and its accompanying regulatory impact analysis are well grounded in applicable statutes and guidance, PHMSA should take further steps to bolster its analysis.

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  • Comments to BLM on the Coastal Plain Supplemental Environmental Impact Statement

    The 2017 Tax Act directed Bureau of Land Management (BLM) to conduct two sales in the Arctic National Wildlife Refuge (ANWR) area known as Coastal Plain totaling at least 400,000 acres by 2024. BLM released a final environmental impact statement (EIS) in September 2019 considering the over 1.5 million-acre area in the ANWR and held the first lease sale in January 2021. Later in 2021, the agency placed a moratorium on all activities relating to BLM’s Coastal Plain leasing program, announced that the analysis conducted in 2019 was legally deficient, and began to prepare a supplemental environmental impact statement. We filed comments on this new EIS and arged that the presentation of climate costs and benefits in the analysis could be made more complete and balanced. 

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  • Policy Integrity Comments Influence Order from Michigan Public Service Commission

    In October 2023, the Michigan Public Service Commission issued an order in the benefit cost analysis (BCA) matter for which we filed comments in June. The order adopts several of our recommendations, and specifically cites us for several of them.

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  • Comments to NHTSA on New Corporate Average Fuel Economy Standards

    In August 2023, the National Highway Traffic Safety Administration (NHTSA) proposed a regulation to strengthen corporate average fuel economy standards for passenger cars, light trucks, and heavy-duty pickup trucks and vans. In a comment letter, we explain that while the Proposed Rule and its accompanying regulatory impact analysis offer useful starting points, NHTSA should take further steps to ensure the complete presentation of regulatory benefits and costs and should select a regulatory option that best promotes social welfare, consistent with the agency’s legal obligations. We also submitted joint comments with a coalition of other environmental groups on NHTSA’s use of the social cost of greenhouses gases in the Proposed Rule.

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  • Policy Integrity Work Shapes FTC Ban on Hidden Fees

    In October 2023, the Federal Trade Commission (FTC) released a proposed rule that bans the use of “junk fees” in transactions including hotel reservations, vehicle rentals, and event ticket purchases. The proposed rule references Policy Integrity and our work more than a dozen times, including both our 2021 petition for rulemaking and our 2023 comment letter supporting the FTC’s authority to issue this regulation.

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