Institute for Policy Integrity logo

Twitter @policyintegrity

Recent Projects

Viewing recent projects in Public Comments
  • Public Comments

    Comments to EPA on Methane Emissions from Oil and Gas Operations

    November 25, 2019

    The Environmental Protection Agency (EPA) proposed revisions to New Source Performance Standards from methane and volatile organic compound (VOC) emissions in the oil and gas sector. We submitted comments focusing on EPA’s flawed and legal economic justifications for the rule.

    Read more

  • Public Comments

    Comments to the State Department on the Proposed Keystone XL Pipeline

    November 18, 2019

    We submitted comments on the U.S. Department of State’s supplemental environmental impact statement for the proposed Keystone XL Pipeline project. A federal district court ruled that the agency’s original impact analysis was inadequate, failing to take all relevant information into account when projecting that the pipeline would not affect total crude oil production. The Department’s new analysis projects that the pipeline will likely increase total crude oil production by only partially offsetting production that would have occurred elsewhere under a “no action” scenario, but irrationally fails to account for this substitution effect when projecting the pipeline’s economic benefits. Our comments argue that the Department continues to violate NEPA by its lopsided treatment of the pipeline’s costs and benefits, through not only its inconsistent treatment of substitution effects but also its failure to assess the pipeline’s climate-related impacts through monetization.

    Read more

  • Public Comments

    Comments to EPA on Water Quality Trading Proposals

    November 18, 2019

    The Environmental Protection Agency (EPA) requested input on policy approaches to promote market-based programs that will improve water quality. We submitted comments suggesting that EPA provides additional clarity, works to avoid undermining key permitting goals, and considers using alternate market-based structures before reissuing its proposals.

    Read more

  • Public Comments

    Comments to Colorado on Participation in Centralized Electricity Markets

    November 15, 2019

    The Colorado Public Utilities Commission is evaluating different options for electric utility participation in centralized electricity markets, as part of the Colorado Transmission Coordination Act. We submitted comments encouraging the Commission to move the state to a centralized market, which would help accomplish energy goals and would benefit generators, utilities, and customers.

    Read more

  • Public Comments

    Comments to the New York Public Service Commission on Resource Adequacy

    November 8, 2019

    We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.

    Read more

  • Public Comments

    Comments to DOE on Conservation Standards for General Service Lamps

    November 4, 2019

    The Department of Energy (DOE) made an initial determination that energy conservation standards for general service incandescent lamps do not need to be amended, even though improved efficiency is technologically feasible and a new standard would save consumers billions of dollars. We submitted comments detailing the flaws of DOE’s economic justification for its proposed decision.

    Read more

  • Public Comments

    Comments to Massachusetts on Clean Peak Energy Standards

    October 30, 2019

    The Massachusetts Department of Energy Resources is adopting a program that incentivizes the adoption of energy storage resources with the aim of displacing high-pollution resources during peak periods of energy use. We submitted comments that explain potential risks of energy storage integration and encourage Massachusetts to adjust its clean peak policies to maximize the emissions reduction potential of the state’s energy storage resources.

    Read more

  • Public Comments

    Comments to BLM on Willow Master Development Plan

    October 29, 2019

    The Bureau of Land Management (BLM) released its environmental impact analysis of the Willow Master Development Plan, estimating the project will produce more than 260 million metric tons of greenhouse gas emissions. We submitted joint comments asking BLM to monetize the real-world climate effects of those emissions using the social cost of greenhouse gases.

    Read more

  • Public Comments

    Comments to EPA on TSCA Chemicals Regulation

    October 28, 2019

    The Environmental Protection Agency (EPA) is proposing to regulate four chemicals that have serious environmental and health risks. We submitted comments supporting EPA and suggesting ways the agency can strengthen its proposal and, additionally, urging EPA to reexamine its decision not to regulate a fifth chemical.

    Read more

  • Public Comments

    Comments to BLM on New Mexico Oil and Gas Lease Sale

    October 28, 2019

    The Bureau of Land Management (BLM) released its environmental assessment of a February 2020 lease sale in the Carlsbad Field Office region of New Mexico. We submitted joint comments asking BLM to monetize the real-world climate impacts of projected emissions using the social cost of greenhouse gases.

    Read more