Search Climate Insights Directory

The Institute for Policy Integrity outlines recommendations for the U.S. Department of the Interior's review of the federal coal program, aiming to increase taxpayer revenue, reduce greenhouse gas emissions, and align land management with national climate goals.

The Institute for Policy Integrity recommends that the agency expand its use of 'option value'—the value of delaying leasing to resolve uncertainties—and incorporate downstream greenhouse gas emissions into its decision-making process for the 2017-2022 offshore leasing program.

The document provides a framework for the Bureau of Land Management (BLM) to select a power sector model for its programmatic environmental impact statement (PEIS), specifically evaluating the Bureau of Ocean Energy Management’s MarketSim, the U.S. Energy Information Administration’s National Energy Modeling System (NEMS), and ICF International’s Integrated Planning Model (IPM). It emphasizes the necessity of balancing model complexity against transparency in the selection process.

The document argues that the Supreme Court's stay on the Clean Power Plan does not prohibit the EPA from continuing preparatory implementation work, nor does it automatically delay or 'toll' compliance deadlines.

The Institute for Policy Integrity argues that the FDA's proposed restriction on artificial tanning sunlamps requires a stronger justification, specifically by improving risk acknowledgment assumptions, accounting for negative externalities and health benefits, recognizing the addictive nature of tanning, and incorporating existing state regulations into the cost-benefit analysis.

The federal coal leasing program is failing to provide taxpayers with the fair market value of coal extracted from public lands, resulting in losses of up to $1 billion annually. This is attributed to coal companies exploiting loopholes, uncompetitive bidding practices, and fiscal terms that ignore coal's export value and the environmental externalities associated with its production.

The document highlights the potency of methane as a climate pollutant and the potential for federal regulations to reduce U.S. natural gas production leaks and venting by up to 50% using existing technologies.

The Institute for Policy Integrity has challenged the Office of Information and Regulatory Affairs (OIRA) over significant delays in reviewing two Department of Labor rules. The rules on Occupational Exposure to Crystalline Silica and Occupational Injury and Illness Recording and Reporting Requirements have been under review for 764 and 483 days, respectively, far exceeding the 90-day framework established by Executive Order 12866. The organization argues that such delays create public costs and uncertainty, urging OIRA to either release the rules, return them to the agency, or disclose the reasons for the delay.

The Institute for Policy Integrity recommends that the Bureau of Consumer Financial Protection clearly define regulatory goals to evaluate policy effectiveness and conduct retrospective analyses of mortgage servicing rules. The organization also suggests improving consumer disclosures through additional testing, timing adjustments, and more balanced information on interest rate adjustments.

The Institute for Policy Integrity advocates for the U.S. Parole Commission to implement swift, proportional responses to minor parole violations and individually-tailored release plans to reduce recidivism and public costs.

The Institute for Policy Integrity provided recommendations to HUD on two proposals: the Emergency Solutions Grant program, which shifts focus from short-term emergency housing to long-term homelessness prevention, and improvements to the Homeless Management Information Systems (HMIS). The Institute advocates for evidence-based decision-making under the HEARTH Act of 2009, the collection of both pre- and post-intervention data to monitor long-term effects, and the implementation of national data collection standards to facilitate nationwide research and reduce reliance on client self-reporting.

The Institute for Policy Integrity calls on the EPA to revise outdated New Source Performance Standards for nitric acid plants, specifically requesting updated NOx standards based on cost-benefit analysis and the inclusion of nitrous oxide (N2O) as a regulated pollutant due to its impact on public health and the climate.

The Institute for Policy Integrity argues for a narrow definition of "specialized services" to prevent loopholes that could undermine net neutrality and advocates for applying neutrality rules to wireless services to avoid investment mismatches between wireless and wireline infrastructure.

The paper argues that standard cost-benefit analysis, specifically the use of discount rates, often renders future climate benefits nearly worthless and fails as a substitute for a moral theory regarding obligations to future generations.

The Institute for Policy Integrity supports the EPA's proposed actions to reduce toxic emissions from boilers and incinerators but argues that the agency should refine its cost-benefit analysis to allow for more stringent standards. The organization recommends that the EPA implement periodic energy audits, adopt a longer time horizon for analysis, and more thoroughly evaluate regulatory alternatives such as switching to cleaner fuels to maximize public health and economic benefits.

The Institute for Policy Integrity argues that the EPA's analysis of the Kerry-Lieberman climate bill is incomplete because it only addresses costs and ignores the potential economic benefits. The author notes that a previous independent analysis of the Waxman-Markey bill found a benefit-to-cost ratio of approximately 9:1, estimating benefits between $750 billion and $1 trillion from 2012 to 2050, and suggests that a similar benefit analysis is necessary for the Kerry-Lieberman bill before the Senate votes.

A reworked analysis by the Institute for Policy Integrity indicates that transitioning large buildings in New York City away from residual heating oil could save up to 259 lives annually. The report utilizes three distinct methodologies—including nickel concentration comparisons and city data—to arrive at consistent estimates regarding the health impacts of soot and toxic chemicals released by residual oil boilers.

The CLEAR Act proposes a carbon price with 100% permit auctioning and consumer rebates to stimulate investment in energy technologies and protect taxpayers from rising energy costs.

The Institute for Policy Integrity and other organizations challenge the Bureau of Land Management's (BLM) proposal to delay the 2016 Waste Prevention Rule, asserting that the agency's economic analysis—specifically regarding the social cost of methane—is inconsistent with scientific and legal standards. They state that the rule's annual benefits exceed its costs by up to $200 million.

The document advocates for a broad interpretation of the National Environmental Policy Act (NEPA), arguing that agencies must analyze indirect environmental impacts beyond proximate effects, specifically in the context of a Surface Transportation Board decision regarding a railway in Utah's Uinta Basin.