Recent Projects

The U.S. District Court for the Northern District of California vacated the Bureau of Land Management's repeal of an Obama-era rule that was designed to reduce wasteful venting of methane from natural gas operations on federal lands. The court ruled in part that it was arbitrary for the Trump Administration to have reduced the estimate of the social cost of methane from $1300 per ton down to just $176 per ton by excluding from consideration any climate effect occurring outside U.S. borders. Policy Integrity has worked for years to build the case against the so-called “domestic-only” estimate of climate costs.

A proposed oil and gas lease sale in Utah would offer over 100,000 acres located in areas valuable for recreation, wildlife, environmental conservation, cultural use, and tourism. We submitted comments detailing how the Bureau of Land Management’s environmental assessment neglects its duties to manage public lands for multiple use and consider more limited leasing scenarios. BLM also ignores the option value of delaying the leasing decision and, therefore, is unlikely to obtain fair market value for the nominated land parcels.

The Department of Energy (DOE) asked for input on conducting its national impact analysis, including on market failures, its emissions analysis, and monetization of benefits of emissions reductions. We submitted comments suggesting that DOE continue to monetize the full climate benefits of emissions reductions using the best available estimates of the social cost of greenhouse gases. 

The Department of Energy (DOE) asked for input on conducting its national impact analysis, including on market failures, its emissions analysis, and monetization of benefits of emissions reductions. We submitted comments suggesting that DOE continue to monetize the full climate benefits of emissions reductions using the best available estimates of the social cost of greenhouse gases. 

We filed a brief in the D.C. Circuit supporting a challenge to the Environmental Protection Agency’s (EPA) decision to revoke the waiver of preemption that allowed California (and more than a dozen states following California's standards) to set critical auto emission standards to further restrict greenhouse gases and other harmful air pollutants. EPA wrongfully concluded that it has virtually unconstrained authority to revoke a preemption waiver under Section 209(b) of the Clean Air Act. We explain how the agency overlooks key countervailing principles and misconstrues the purpose and mechanics of the waiver provision.  

The Environmental Protection Agency (EPA) is proposing to amend the 2015 New Source Performance Standards (NSPS) for residential wood heating devices, purporting to respond to retailer needs in the wake of the COVID-19 pandemic. Our comments detail how how the proposal contradicts the Clean Air Act’s mandate and longstanding agency guidance. The proposed rule will, even under the agencies’ own analysis, cause net harms to the public without providing any reasonable justification.

Under recent revisions to the Supplemental Nutrition Assistance Program, nearly 700,000 current beneficiaries would lose eligibility—harming the health of those individuals and likely causing economic disruption in the food sector. We filed an amicus brief in a federal lawsuit challenging the rule, detailing how the Department of Agriculture’s analysis fails to assess the profound and widespread costs of substantial disenrollment from SNAP assistance. Our brief was cited several times in the State Plaintiffs' reply brief to support their argument that the federal government did not adequately consider the indirect costs of the rule. 

The Federal Energy Regulatory Commission proposed changes to its electric transmission incentives, which aim to spur the deployment of technologies that enhance reliability, efficiency, and capacity of transmission facilities. We submitted comments identifying significant problems with the proposal, including its reliance on a benefit-cost ratio for project selection.