Recent Projects

In February 2024, EPA finalized amendments to its Risk Management Program (RMP), under Section 112(r) of the Clean Air Act, to better protect vulnerable communities from chemical disasters that release toxic air pollution. In line with Policy Integrity’s recommendations, the final rule has been strengthened relative to the proposal and includes considerably more attention to the issues of underreporting, unquantified benefits, and the risks of catastrophic incidents. EPA has further improved the final rule to include consideration of climate change-related hazards in line with Policy Integrity’s recommendation to cover climate change-exacerbated hazards in addition to climate change-caused hazards. This will be increasingly important as the risks and magnitude of future chemical incident damages will likely only grow as climate change exacerbates severe weather that can spur power outages and chemical disasters.

In January, the Department of Energy proposed to strengthen its energy efficiency standards for fans and blowers, which would save consumers in energy costs and reduce pollution that harms public health and exacerbates climate change. Our comment offered several suggestions to improve the rule and accompanying analysis.

The Institute for Policy Integrity submitted comments to the New York State Energy Research and Development Authority (NYSERDA) regarding its proposal for a new cost-effectiveness test for updates to the state energy conservation construction code. We recommended changes and clarifications that NYSERDA and the Code Council can make to improve their evaluation criteria. 

Policy Integrity commented on the Department of Treasury's proposed regulation to implement the Section 45V tax credit for clean hydrogen production from the Inflation Reduction Act. This tax credit subsidizes the production of hydrogen based on its emissions intensity. Our comments leveraged our expertise on the electric grid to advise Treasury on how to accurately measure the emissions intensity of hydrogen from grid-connected electrolyzers.

On February 23rd, Policy Integrity submitted comments to EPA on its draft Scientific Integrity Policy. The draft Policy appropriately clarifies that economic analyses are protected by the same integrity policies as other scientific assessments, but it currently cites EPA's 2010 Guidelines for Performing Economic Analyses as the only example of a best-practice document that "should be followed" when assessing benefits, costs, and economic impacts. Several key elements of those 2010 guidelines are out of date, notably the recommendations on discount rates. Our comments offer a simple redline to ensure that other documents that meet the standards for objectivity--like the updated Circular A-4, or the pending ecosystem service guidance--could also fall under the Policy's proposed protections. 

Policy Integrity submitted comments to the New York State Public Service Commission (NYPSC) regarding the section of the Climate Leadership and Community Protection Act (CLCPA) that amends the Public Service Law to add a new section (Section 66-p), which requires, among other things, that, by 2040, “the statewide electrical demand system will be zero emissions.” NYPSC had posed several questions about how it should interpret the requirements for 2040 under the new Public Service Law provision.