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Recent Projects

  • Comments on the New York Climate Action Council’s Draft Scoping Plan

    The Climate Leadership and Community Protection Act (CLCPA or the Act) committed New York to an ambitious set of changes across all sectors of the economy. The development of a Scoping Plan, as called for by the Act, will help steer New York's agencies--and legislature--as they initiate those changes. Policy Integrity's comments focus on the Electricity and Gas System Transition chapters of the Draft Scoping Plan. In addition to voicing support for several of the measures listed in that plan, those comments encourage adoption of further measures in a final version of the plan. Those additional measures would support greater coordination of electricity sector stakeholders' decisions and would create a greater degree of certainty about the nature and pace of gas system transition.

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  • Enhancing Consideration of Time Frames in Cost-Benefit Analysis Cover

    Enhancing Consideration of Time Frames in Cost-Benefit Analysis

    Federal agencies frequently provide no justification for their analytical time frame when analyzing the costs and benefits of a policy. This is true even when there are costs and benefits that clearly occur beyond the time frame chosen by the agency. In so doing, agencies risk overlooking key long-term impacts that may justify more stringent regulation.

    This report argues that the Office of Management and Budget (OMB) should take steps to improve how agencies consider analytical time frames in their cost-benefit analyses.

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  • Measuring the Benefits of Power Plant Effluent Regulation Cover

    Measuring the Benefits of Power Plant Effluent Regulation

    The 2020 Steam Electric Reconsideration Rule and Potential Future Methods

    EPA is considering regulations that would clean up the wastewater discharges from power plants, after they were stalled and then rolled back under the Trump administration. As it conducts that analysis, this report urges EPA to provide a robust assessment of the benefits of the regulation, improving on analysis that was conducted in the Obama era. The report reviews the economic framework, literature, and analyses performed to support both the original Obama-era rule and Trump-era revisions, building on Davis Noll and Rothschild (2021), which detailed numerous impacts of the 2020 Rule that EPA neglected to examine. This review highlights key considerations that will strengthen future regulations. 

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  • Comments to EPA on Proposed Transport Rule

    In April 2022, EPA proposed a Federal Implementation Plan (FIP) to reduce interstate transport of ozone pollution using the Clean Air Act's Good Neighbor Provision. We submitted comments supporting the Proposed FIP and recomming that EPA select the regulatory alternative that maximizes net benefits and revise and expand its distributional analysis to better reflect the impacts of the Proposed FIP on vulnerable groups. We also submitted joint comments with a coalition of environmental groups supporting EPA's use of the social cost of greenhouse gases in the Proposed FIP.

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  • Joint Comments to SEC on its Proposal to Enhance and Standardize Climate-Related Disclosures

    Together with the Environmental Defense Fund and Professor Madison Condon of Boston University School of Law, we submitted three sets of comments to the Securities and Exchange Commission (SEC) in support of its Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (Proposed Rule). The Proposed Rule would require publicly traded companies to disclose important information about the extent to which climate change is already affecting their financial performance, their approach to climate-related risk management, their climate-relevant governance structures, and their greenhouse gas emissions, which serve as a proxy for exposure to risk from policy- and market-driven shifts to a clean-energy economy.

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  • Joint SC-GHG Comments on Proposed DOE Standards for Room Air Conditioners and Pool Heaters

    Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for room air conditioners and pool heaters. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards, even though the standards would be cost-benefit justified without considering any climate benefits. We also encourage DOE to expand upon its rationale for adopting a global damages valuation and for the range of discount rates it applies to climate effects.

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  • Regulating Immortal Accounts Cover

    Regulating Immortal Accounts

    How the FTC Can Limit Unwanted Data Retention

    The report argues that an FTC rule requiring reasonable cancellation practices for all market actors and providing clear and specific guidelines would address the harms of immortal accounts. Such regulation would fall under the FTC’s authority and advance the Commission’s mission to protect consumers and competition by preventing deceptive, unfair, and anticompetitive business practices.

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  • Comments to EPA on Proposed Heavy-Duty Vehicle Emission Standards

    In March 2022, EPA proposed standards to regulate emissions of nitrogen oxides and particulate matter from heavy-duty vehicles beginning with Model Year 2027. Policy Integrity submitted comments recommending that EPA strengthen these crucial standards in order to fulfill EPA's statutory duty to set standards "reflecting the greatest degree of emission reduction achievable." We also made a number of recommendations designed to ensure that EPA is properly comparing regulatory alternatives and accounting for the benefits of strong regulation.

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  • Amicus Brief in Fifth Circuit Supporting Reversal of Injunction on the Social Cost of Greenhouse Gases

    In this amicus brief, we explain how the Interagency Working Group based its climate-damage valuations on voluminous and expert science, and that its approach followed regulatory guidance and precedent. In particular, the brief supports the Working Group's selection of discount rates and geographic scope, explaining how those choices followed expert consensus and were consistent with agency treatment of other regulatory impacts.

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  • Comment Letters on FERC’s Proposed Policy Statements for Natural Gas Infrastructure

    In February, the Federal Energy Regulatory Commission released two policy statements that acknowledged the Commission’s role in shaping the nation’s transition to a low-carbon future and called for the consideration of climate impacts in pipeline certificate proceedings. Today, the Institute for Policy Integrity filed two comment letters to these proposed policy statements.

    In one of our comment letters—filed jointly with over two dozen legal scholars from institutes across the country—we rebut arguments from opponents of the policies that the Commission lacks authority to consider climate effects in its oversight of natural gas infrastructure under the Natural Gas Act.

    In our other comment letter, we explain that the policy statements serve as an important step toward ensuring that upstream and downstream emissions are properly considered in line with the Commission’s statutory obligations, but provide several suggestions for improvements.

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