Recent Projects

We submitted comments to the New York Public Service Commission to voice our support for a petition concerning the impacts of climate change on utility infrastructure. Our comments emphasize that it is imperative for public utilities to identify and assess the risks that climate change poses to their assets and operations.

In a recent presentation, the New York Independent System Operator (NYISO) posed key questions related to potential buyer-side mitigation reforms. We submitted comments that provide three recommendations to NYISO.

Climate change presents grave risk across the U.S. economy, including to corporations, their investors, the markets in which they operate, and the American public at large. The Securities and Exchange Commission (SEC) recently requested public input on climate change disclosures, posing several questions related to the development of new disclosure regulations and the enforcement of existing regulations. We worked with several partners to submit comments to the SEC, providing 15 major recommendations.

As the climate crisis intensifies, it is crucial that policymakers strengthen protections from the dangers of climate change to our nation’s financial system and the millions of people who rely on it to sustain the American economy. The Institute for Policy Integrity, alongside several partners, has founded the Initiative on Climate Risk and Resilience Law to advocate for smarter policies on this issue.

In May, EPA announced its intention to rescind a 2020 rule entitled "Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process." Policy Integrity submitted comments in support of this decision based on the view that the 2020 rule is unnecessary, unsupported by any evidence of need, and inconsistent with best practices for cost-benefit analysis. We attached joint comments that Policy Integrity submitted during the original rulemaking which made these arguments in addition to demonstrating specifically how the rule broke from cost-benefit best practices by (1) devaluing indirect benefits, (2) subjecting benefit calculations to stricter standards than cost calculations, and (3) raising the bar for evidence of causality in a manner that excludes studies highly significant to EPA’s cost-benefit analysis.

The New Jersey Board of Public Utilities (BPU) released a straw proposal for its Solar Successor Program. We submitted comments addressing a question about solar projects' potential benefits to environmental justice (EJ) communities. Our comments encourage BPU to consider the inclusion of an environmental justice adder and reommend that BPU explore an adder that would deliver material benefits to EJ communities. 

The Federal Energy Regulatory Commission (FERC) issued a notice of inquiry on how to revise its policy on certifying the construction and operation of interstate natural gas transportation facilities. We submitted comments providing numerous recommendations for how FERC can improve its evaluation of environmental impacts and methodology for determining whether there is need for a proposed project.

The Department of Energy proposed revisions to its procedures and policies for considering new energy conservation standards across a range of consumer products and commercial equipment. We submitted comments offering support for the proposed revisions and making additional recommendations. Our recommendations include weighing a full range of environmental and consumer effects, incorporating the consideration of distributional justice, and reviewing the selection of discount rates. 

The Rail Tie Wind Project would offset approximately 900,000 metric tons of carbon dioxide emissions annually compared to typical U.S. electric generation. We submitted comments encouraging the Western Area Power Administration to provide context for those emission offsets by using the social cost of greenhouse gases.