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Recent Projects

  • Court Filings

    Amicus Brief on Dust-Lead Hazard Standards

    January 22, 2020

    The Environmental Protection Agency (EPA) finalized a rule revising standards for lead found in dust on floors, window sills, and in soil. Our amicus brief critiques the rule, which forgoes net beneficial options in favor of weaker standards that will cause significant harms to public health.

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  • Public Comments

    Comments to EPA on Water and Air Pollution Limitations from Electric Power Generation

    January 21, 2020

    The Environmental Protection Agency (EPA) proposed to weaken technology standards adopted in 2015 that act as crucial controls on effluent and emissions from electric power generation. Our comments focus on EPA’s flawed legal and economic justifications for the proposed rule, which contravenes the Clean Water Act, creates harmful incentives to delay compliance with guidelines, and relies on flawed cost-benefit analysis. We also submitted joint comments that detail how EPA severely undervalues the proposed rule’s climate costs and must monetize the full social cost of carbon using the best available data and methodologies.

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  • Court Filings

    Amicus Briefs on Homeland Security’s “Public Charge” Rule

    January 21, 2020

    In October, the Department of Homeland Security finalized the “public charge” rule, which seeks to deny lawful permanent residency to immigrants who have participated in public assistance programs like Medicaid, the Supplemental Nutrition Assistance Program, and the Section 8 housing voucher program. Multiple federal district courts have since enjoined the rule from taking effect and Policy Integrity filed amicus briefs supporting those injunctions on appeal. Our briefs explain how the Department failed to meaningfully assess many of the substantial social costs of the large-scale disenrollment from public assistance programs that will result from the rule, and also failed to identify any significant social benefits from the rule.

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  • Public Comments

    Comments to EPA’s Chartered Science Advisory Board

    January 10, 2020

    We submitted four comments in advance of the Environmental Protection Agency’s (EPA) January 2020 meeting of its Chartered Science Advisory Board (SAB).

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  • Reports

    Look Before You Lease

    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.

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  • Public Comments

    Comments to BLM on Proposed Farmington Drilling Projects

    January 6, 2020

    The Bureau of Land Management’s (BLM) Farmington Field Office in New Mexico released an addendum to its environmental assessment for eighty-six drilling applications. The addendum estimates that the projects, in total, would result in more than 483 million metric tons of carbon dioxide-equivalent over the lifetimes of the assessments. BLM’s analysis, however, fails to consider the climate impacts of these emissions, which would amount to more than $25 billion. Our comments ask that BLM provide monetized estimates of these real-world climate impacts using social cost of greenhouse gases metrics.

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  • Public Comments

    Comments to FERC on Putnam Expansion Project

    January 6, 2020

    The Putnam Expansion Project involves the construction and installation of natural gas infrastructure that will result in downstream emissions of approximately 3.26 million metric tons carbon dioxide-equivalent each year. Our comments to the Federal Energy Regulatory Commission (FERC) focus on its environmental assessment of the project, which provides unclear and inadequate analysis of the emissions and their climate impacts. We urge FERC to monetize climate damages by using social cost of greenhouse gas metrics.

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  • Public Comments

    Comments on HHS Changes to Grant Recipient Regulations

    December 19, 2019

    The Department of Health and Human Services (HHS) is proposing to change regulations governing grant recipients, such as foster-care and adoption programs. The rule would allow discrimination on the basis of non-merit factors including sexual orientation or gender identity, likely leading to more denials of service to qualified LGBT individuals and same-sex couples. We submitted comments detailing how HHS fails to provide any analysis of the proposed rule’s costs.

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  • Public Comments

    Comments to FERC on Offshore Wind Transmission

    December 19, 2019

    Due to a significant buildout of offshore wind in the mid-Atlantic as a result of falling costs and state policy commitments, new offshore transmission will be required. However, the market rules for the nation’s largest electricity grid operator, PJM, currently provide no practical path for the development of open-access transmission to connect planned but not-yet-developed offshore wind generation. We submitted comments urging the Federal Energy Regulatory Commission to eliminate barriers to these projects, lowering transmission costs and ensuring just and reasonable rates.

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  • Policy Briefs

    Assessing the Rationale for the EPA’s Proposed Regulatory Science Rule

    December 19, 2019

    The U.S. Environmental Protection Agency (EPA) is considering a new policy that would prohibit the agency from issuing regulations that rely on studies whose underlying data are not publicly available. While the EPA claims it is pursuing this policy in the interest of transparency, we argue that such a prohibition would greatly hinder, rather than help, the rulemaking process and would likely result in undesirable regulatory outcomes that fail to maximize economic welfare.

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