Institute for Policy Integrity logo

Twitter @policyintegrity

Publications

Viewing all publications in Reports
  • Beneath the Surface
    Report

    Beneath the Surface

    The Concealed Costs of the Clean Water Rule Rollback

    By Bethany Davis Noll, Peter Howard, Ph.D., Max Sarinsky, Jason Schwartz, and Jeffrey Shrader, Ph.D.
    April 27, 2020

    In restricting the scope of the Clean Water Act through two regulatory rollbacks, the Environmental Protection Agency and Army Corps of Engineers claim that the estimated compliance-cost savings exceed the environmental harms (in the form of forgone benefits). Yet these analyses suffer from severe methodological flaws. And correcting the analyses would very likely show that the rollbacks are net costly to society, depriving the public of potentially billions of dollars in annual forgone benefits. As detailed in this report, the agencies’ failure to meaningfully assess the substantial harms that will result from their rollbacks violates both regulatory precedent and the agencies’ legal obligations.

  • Carbon Pricing in Wholesale Electricity Markets
    Report

    Carbon Pricing in Wholesale Electricity Markets

    An Economic and Legal Guide

    By Matt Butner, Bethany Davis Noll, Justin Gundlach, Burcin Unel, and Avi Zevin
    March 25, 2020

    This report explains how carbon-pricing rules in organized wholesale electricity markets can improve economic efficiency. It then explores the economic principles and legal requirements for RTOs, states, and the Federal Energy Regulatory Commission to consider when implementing a carbon-pricing rule in organized wholesale electricity markets. And it identifies several policy-design approaches that, to varying degrees, meet those economic principles and are likely to be found legally permissible.

  • Look Before You Lease
    Report

    Look Before You Lease

    Reducing Fossil Fuel Dominance on Public Lands by Accounting for Option Value

    By Jayni Hein, Joy Kim, and Sam Smith
    January 7, 2020

    While the Trump administration’s goal of “energy dominance” has increased the public lands available for oil and gas development, no effort has been made to modernize the leasing system, even in the face of climate change. Our report explains how option value—which accounts for the informational value gained by delaying leasing decisions—can and should be factored into the Bureau of Land Management’s land use planning processes. Accounting for option value at multiple stages of the land use planning process would significantly improve BLM’s public lands stewardship, better protect the environment, and regain some of the economic and strategic advantages it has ceded to private developers. The report also describes case studies where BLM’s failure to consider option value has led to costly litigation and missed opportunities.

  • Getting the Value of Distributed Energy Resources Right
    Report

    Getting the Value of Distributed Energy Resources Right

    Using a Societal Value Stack

    By Justin Gundlach and Burcin Unel, Ph.D.
    December 3, 2019

    Our report notes the growing presence of distributed energy resources, like solar panels and energy storage installations, and explains how they should be compensated for providing electricity services valued by utilities and their customers. Currently, 40 states use net energy metering programs to compensate DERs. We describe a promising alternative, “value stacking,” which better reflects DERs’ value, and provide suggestions for how to implement this approach.

  • Pipeline Approvals and Greenhouse Gas Emissions
    Report

    Pipeline Approvals and Greenhouse Gas Emissions

    By Jayni Hein, Jason Schwartz, and Avi Zevin
    April 9, 2019

    In light of growing public awareness of the environmental effects of pipeline projects, the Federal Energy Regulatory Commission (FERC) has faced competing pressures regarding how to balance the need for new natural gas pipelines with their environmental consequences. Concerns about greenhouse gas (GHG) emissions and resulting climate change effects have become a flashpoint in the debate. Our report examines the legal context surrounding FERC’s evaluation of the environmental impacts of proposed interstate natural gas pipelines. We look at FERC’s obligations under the Natural Gas Act and the National Environmental Policy Act, as well as potential improvements the agency can make to its analyses to better inform policy makers and the public about the impacts of proposed projects.