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The report argues that carbon pricing in wholesale electricity markets can reduce CO2 emissions at the lowest cost and improve economic efficiency. It focuses on the role of Regional Transmission Organizations (RTOs) in pricing emissions directly within energy market operations and outlines the legal and economic frameworks necessary for the Federal Energy Regulatory Commission, states, and RTOs to implement such rules.

The Institute for Policy Integrity critiques proposed PJM capacity market reforms, specifically the expansion of the Minimum Offer Price Rule (MOPR), arguing that penalizing resources receiving state payments for avoided emissions would reduce market efficiency and potentially increase costs for consumers.

The Institute for Policy Integrity opposes the Department of the Interior's intent to roll back the 2016 Blowout Preventer Systems and Well Control Rule, asserting that the agency must analyze the lost societal benefits—including safety, environmental risk reduction, and reduced fatalities—before proceeding with the repeal.

The Institute for Policy Integrity contends that the Department of Education, under Secretary Betsy DeVos, acted in an "arbitrary and capricious" manner by delaying the 2016 Borrower Defense Rule three times. The brief asserts that the Department ignored the harms these delays caused to student borrowers who were defrauded by for-profit educational institutions, while focusing only on the financial savings for the federal government and the institutions themselves.

The report challenges the assumption that energy storage automatically reduces greenhouse gas emissions, noting that certain situations can lead to increased emissions. It advocates for policy reforms at state and federal levels to correct poor incentives, specifically recommending the accurate pricing of greenhouse gas externalities, the removal of entry barriers for storage systems, and the elimination of obstacles preventing storage from accessing multiple value streams for its services.

The Institute for Policy Integrity submits that the New York Public Service Commission correctly applied the Social Cost of Carbon to internalize the external costs of carbon emissions when pricing zero-emissions credits for nuclear generators. This mechanism supports the state's Clean Energy Standard goal of reaching 50% renewable generation by 2030 by preventing potential pollution increases that would occur if nuclear plants closed.

The Institute for Policy Integrity asserts that the U.S. Forest Service's final approval of the West Elk coal mine expansion ignores significant climate costs. While the agency quantified the increase in greenhouse gas emissions, it provided only a generic description of climate effects rather than monetizing the damages, which the author claims would amount to hundreds of millions of dollars. The document argues this omission is arbitrary and illegal, noting that as recently as 2017, agencies used the Interagency Working Group’s social cost of greenhouse gases for similar decisions.

The Institute for Policy Integrity and other environmental groups oppose H.R. 3117, arguing that the act would force federal agencies to ignore or undervalue climate damages and hinder the use of scientifically sound Social Cost of Carbon estimates.

The Institute for Policy Integrity submitted comments to the Federal Highway Administration and the US Army Corps of Engineers, challenging the claim that project-level greenhouse gas emissions are too insignificant to contribute to climate change. The Institute asserts that agencies are required to address climate effects and should follow Circular A-4 and best economic practices by quantifying and monetizing these emissions, noting that the US Army Corps specifically fails to consider downstream emissions from oil drilling.

The Institute for Policy Integrity supports a legal challenge against the Department of Housing and Urban Development (HUD) for suspending the 2016 Small Area Fair Market Rent Rule. This rule required public housing agencies to calculate vouchers by zip code by January 2018 to increase affordable housing availability in higher-rent neighborhoods and reduce the concentration of recipients in low-cost areas. The author contends that HUD's suspension of the rule until January 2020 is unlawful because the agency failed to provide a new economic justification or seek public feedback, thereby violating the Administrative Procedure Act.

The Institute for Policy Integrity recommends that California's cap-and-trade program, extended by Assembly Bill 398, set its permit price ceiling at least as high as the social cost of carbon to properly incentivize emissions reductions. The organization also suggests that unsold allowances be preferentially allocated to the price containment reserve with the highest price to better account for the externalities of greenhouse gas emissions.

The report examines the Clean Power Plan, a 2015 EPA rule aimed at reducing carbon dioxide emissions from fossil fuel-fired power plants. It argues that compliance costs are now lower than the EPA's initial Regulatory Impact Analysis suggested due to changes in the electric sector and findings from independent analyses.

The report critiques the Trump administration's attempt to repeal the 2015 Clean Water Rule, asserting that the agencies used a revised economic analysis that violated their own requirements to make the rule appear unjustified. It maintains that the 2015 rule remains cost-benefit justified and that its repeal would result in the loss of significant environmental and economic benefits.

The Institute for Policy Integrity argues that the Bureau of Land Management (BLM) acted irrationally by staying the Waste Prevention Rule—which aimed to stop oil and gas companies from wasting natural gas on public lands—without considering the forgone benefits of the rule. The brief contends that the BLM's justification relied solely on cost savings, ignoring the benefits it had previously used to justify the rule's enactment, and calls for the stay to be vacated.

The Institute for Policy Integrity recommends that the California Air Resources Board enhance its 2017 Scoping Plan Update by using the Social Cost of Methane to assess methane emissions and by monetizing the co-benefits of greenhouse gas reduction measures.

The Institute for Policy Integrity criticizes a 2017 Executive Order requiring the repeal of two regulations for every new one, arguing it ignores the net benefits to public health and safety. The organization urges OIRA to maintain rational rulemaking principles, focus on 'economically significant' actions, and use net costs—including difficult-to-quantify benefits—to set regulatory budgets.

The Institute for Policy Integrity defends the EPA's 2016 supplemental finding on the Mercury and Air Toxics Standards (MATS), asserting that the agency correctly considered regulatory costs and benefits, including indirect and unquantified benefits, in accordance with legal and economic standards.

The report presents recommendations, based on a consensus of former Office of Information and Regulatory Affairs (OIRA) Administrators from both political parties, to strengthen the regulatory review process via executive action. It notes that centralized review by OIRA is intended to improve interagency coordination and the evaluation of qualitative and quantitative costs and benefits of regulations.

The document defends the Clean Power Plan against claims that the EPA overstepped its authority. It asserts that the Plan adheres to the limits of Section 111 of the Clean Air Act, which requires the agency to avoid excessive costs, consider energy supply impacts, and use adequately demonstrated reduction techniques.

The report highlights the risk posed by 'self-bonds' in the coal industry, where companies avoid posting collateral for land and water reclamation. With $3.86 billion in outstanding self-bond obligations nationwide—$2.4 billion of which is held by companies in bankruptcy—the author warns that taxpayers may be forced to fund costly environmental restoration if regulators do not act to curtail this practice.