Recent Projects

In September 2023, the Federal Aviation Administration (FAA) proposed a regulation that would require commercial space operators to limit or dispose of their launches’ orbital debris within 25 years. While the Proposed Rule and its accompanying regulatory impact analysis reasonably explain why orbital debris is a problem and why regulation will help address it, we explain in our comment letter that FAA should take further steps to bolster its analysis.

On December 22nd, the Treasury Department issued a notice of proposed rulemaking to implement the Inflation Reduction Act’s (IRA) 45V tax credit for clean hydrogen production. The proposal would establish rules for how electrolyzers can demonstrate compliance with the IRA’s lifecycle greenhouse gas limits—and thus demonstrate their eligibility for the tax credit. The proposed rule includes robust requirements to avoid greenhouse gas emissions: new clean power, annual matching with a transition to hourly matching in 2028, and contracting within the same regional grid. The approach in this proposal aligns with many of the recommendations the Institute for Policy Integrity made in comments to the Treasury Department. 

In May 2023, the Environmental Protection Agency (EPA) proposed a package of regulations to limit greenhouse gas emissions from fossil fuel-fired power plants under Section 111 of the Clean Air Act. EPA subsequently issued a supplemental notice of proposed rulemaking, re-opening its comment period and soliciting comment on whether to include additional mechanisms to address potential reliability issues. In these comments, we explain why EPA has engaged in reasoned rulemaking and developed a robust administrative record comporting with its mandate to reduce power sector pollution. It remains the Federal Energy Regulatory Commission’s (FERC’s) responsibility to ensure reliable bulk-power system (BPS) operations and to use its corresponding tools to address the wider reliability challenges of the clean energy transition, in coordination with other reliability-related entities.

In October, EPA issued proposed restrictions on the manufacture, processing, and distribution of a chemical called trichloroethylene (TCE). We argue in comments that aspects of the agency’s Economic Analysis of the proposed restrictions could be clarified or expanded upon to better inform policymakers and the broader public about the benefits of ending TCE use.

In August, the National Highway Traffic Safety Administration (NHTSA) proposed to strengthen vehicle fuel-economy standards. Since then, the Environmental Protection Agency has finalized its update to the social cost of greenhouse gases and the Office of Management and Budget has finalized its revisions to Circular A-4. In light of these updates, we submitted a supplemental comment letter reasserting our call for NHTSA to assess regulatory impacts using the best available economics.

Earlier this year, the Council of Environmental Quality (CEQ) published interim guidance on analyzing climate change effects under the National Environmental Policy Act in which it endorsed using the social cost of carbon in environmental analysis. In this supplemental comment letter, we suggest that CEQ specifically endorse the Environmental Protection Agency’s newly-updated climate-damage values when it finalizes the interim guidance.

On December 2nd, EPA released a new methane regulation that includes final updated values for the social cost of greenhouse gas metrics. The updated metrics align with many of the recommendations Policy Integrity made in our comments on the draft values, and our scholarship and analysis were cited heavily in the associated federal documentation.