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  • Testimony in Michigan’s Line 5 Case

    Policy Integrity's Economics Director Peter Howard joined climate scientists and economic experts in written testimony to the Michigan Public Service Commission (MPSC) about the significance of excessive greenhouse gas emissions that would be generated if Enbridge’s Line 5 tunnel siting permit is approved. Howard explained that “the Proposed Project will generate a present value of $41 billion (in 2020 dollars) or more in net monetized climate costs from 2027 to 2070 as compared to the no-action alternative – in other words, the Proposed Project will generate average annual monetized climate costs of approximately $1 billion each year over this period, plus significant unmonetized climate effects and other unquantified pollution costs to human health and the environment.”

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  • Comments to FERC on Joint Federal-State Task Force on Transmission

    We submitted comments to FERC today providing suggested topics for the first meeting of the joint federal-state task force on transmission. Our comments respond to a request for topics related to barriers inhibiting more efficient and effective transmission planning and deployment. We identify two barriers that the task force should discuss -- jurisdictional issues related to transmission siting and the lack of a standardized cost benefit analysis rubric for transmission projects.

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  • Building a New Grid without New Legislation: A Path to Revitalizing Federal Transmission Authorities Cover

    Building a New Grid without New Legislation: A Path to Revitalizing Federal Transmission Authorities

    Published Ecology Law Quarterly

    In the absence of legislation, critical long-distance transmission can be developed by applying existing federal legal authorities. A number of important regulatory and commercial measures have been proposed, including streamlining transmission planning, upgrading existing transmission system components, putting transmission lines underground, and using existing rights-of-way from highways and railroads. Even if these solutions are adopted, however, state siting requirements may prove an important obstacle to developing an efficient, national transmission grid. So, this paper examines legal authorities already available to the Department of Energy and the Federal Energy Regulatory Commission to develop the interstate transmission capacity crucial to the energy transition.

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  • Comments to FERC on Evangeline Pass Expansion Project

    We filed a comment letter with the Federal Energy Regulatory Commission (FERC) regarding their continued failures to meaningfully assess the climate impacts of natural gas infrastructure projects, this time regarding the Evangeline Pass Expansion Project EIS. Two companies have requested authorization to construct and operate a new pipeline, compressor stations and meter stations in Louisiana and Mississippi, which will be used to transport up to 1,100,000 dekatherms per day to an LNG facility for export.

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  • Climate-Society Feedback Effects Cover

    Climate-Society Feedback Effects

    Be Wary of Unidentified Connections

    To ensure policies are based on accurate predictions of climate impacts, it is critical to understand social-ecological system (SES) feedbacks, including how humans change the climate by reacting to a changing climate. Building on recent scholarly work on the topic, this article describes SES interactions and how they can be incorporated into climate policy tools such as the social cost of carbon. The article then proposes a research agenda for the identification, quantification, and integration of climate-society feedbacks into social-cost integrated assessment models (SC-IAMs).

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  • Comments to EPA and USACE on Clean Water Protections

    The Environmental Protection Agency (EPA) and Army Corps of Engineers (USACE) have expressed the intention to repeal the Navigable Waters Protection Rule, which removed critical federal protections on many waterways and has been vacated by a federal court for violating the Clean Water Act. In comments filed to the agencies, we welcome the decision to replace the rule but encourage strong justification for reversing course and point to flaws in the economic analysis for the earlier rule that can support the case for replacing it.

    We previously commented on the rule and its flawed economic justification, published a report on its concealed costs, and filed amicus briefs in court cases that challenged it.

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  • Making Regulations Fair Cover

    Making Regulations Fair

    How Cost-Benefit Analysis Can Promote Equity and Advance Environmental Justice

    To achieve the Biden administration’s ambitious commitments to equity and environmental justice, agencies will need guidance on how to assess and weigh the distributional effects of policy options. This report recommends steps that the Office of Management and Budget (OMB) can take to mainstream equity into agencies’ decisionmaking.

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  • Comments to FERC on the North Baja Xpress Project

    The North Baja XPress Project would provide a significant increase in natural gas compression and transportation, potentially resulting in 9.5 million metric tons or more in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. In October 2020, we submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

    In our August 2021 follow up letter responding to FERC's draft environmental impact statement for the project, we note that the Commission has taken the helpful steps of quantifying direct and downstream emissions, but should still quantify upstream emissions, assess the project's incremental environmental harms, and consider avenues to mitigate emissions.

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  • Comments to FERC on East 300 Upgrade Project

    The East 300 Upgrade Project could result in the emission of over 2.3 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. In March, we submitted comments encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions and weigh its climate impacts using the social cost of carbon. In August, we followed up with a comment letter regarding the Commission's continued failures to meaningfully assess climate impacts in the project's Draft Environmental Impact Statement.

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  • Comments to FERC on PJM MOPR Reform

    We submitted comments to the Federal Energy Regulatory Commission (FERC) encouraging the agency to accept PJM’s proposed changes to the Minimum Offer Price Rule, which recognizes that generation-based externality payment for clean electricity resources can be welfare-enhancing, and removes the artificial barrier to market entry for resources that receive payments under state climate policies created by the previous rule.

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