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The Institute for Policy Integrity critiques a proposal for New Jersey to exit RGGI, noting that the analysis fails to account for long-term power plant investments, the loss of state revenues from allowance sales, and the global impact on greenhouse gas emissions. It further argues that the proposal's 'Fixed Price Proposal' lacks a concrete policy mechanism to achieve its modeled $7 price.

The report discusses the potential for artificial intelligence to increase efficiency in federal rulemaking while warning that its use must complement, rather than replace, rigorous human reasoning to avoid flawed regulations.

The document asserts that the second Trump Administration's efforts to eliminate environmental justice (EJ) analyses do not override existing legal obligations. It highlights that agencies may still be required to consider EJ impacts under specific statutory provisions, the National Environmental Policy Act (NEPA), and the Administrative Procedure Act (APA). Furthermore, it argues that race-neutral EJ analyses, such as those focusing on economically disadvantaged communities, remain legally viable under the Equal Protection Clause, contrary to administration claims following the Loper Bright decision.

The Institute for Policy Integrity warns that the EPA is implementing unsupported changes to its toxic chemicals risk evaluation framework and specific assessments, such as for formaldehyde, which may lead to flawed decisions and inadequate safety standards.

The report examines the Trump administration's efforts to dismantle environmental justice initiatives, arguing that the legal justifications for these rollbacks are weak. It specifically addresses the impact of Supreme Court rulings on affirmative action, asserting that while such decisions impose constraints, they do not make environmental justice initiatives categorically unlawful nor prevent the government from considering the historical legacies of racism.

The essay addresses the legal vacuum left by Loper Bright Enterprises v. Raimondo regarding how courts should 'fix the boundaries' of agency discretionary authority. It argues that courts should utilize a statute's purpose, structure, and historical context to define these boundaries, subsequently applying the State Farm arbitrary-and-capricious standard to evaluate the agency's decision-making.

The report asserts that FERC is legally obligated under the Natural Gas Act and the Administrative Procedure Act to conduct environmental justice analyses by considering the existing burdens of communities where new gas infrastructure is proposed. It argues that ignoring these compounding social and environmental costs would violate the requirement for reasoned decisionmaking, regardless of recent administrative memoranda directing agencies to avoid such assessments.

The report examines New York State's progress toward the climate requirements of the Climate Leadership and Community Protection Act (CLCPA), noting that the state is not on track to meet these goals and has cited costs as a reason for infeasibility.

The report argues that the Nuclear Regulatory Commission (NRC) possesses the legal authority to license small modular reactors (SMRs) as "utilization facilities" under the Atomic Energy Act of 1954. It contends that the NRC's classification is reasonable, supported by the 2024 ADVANCE Act, and justified by the quantities of special nuclear material used in most SMRs. The author suggests that regulatory improvements should be pursued through collaboration between developers and the NRC rather than through litigation, which risks allowing non-expert judges to decide licensing requirements.

The report examines the impact of New York's CLCPA greenhouse gas accounting method, which differs from the UNFCCC standard. It finds that the CLCPA approach increases the distance to statutory targets and alters cost-effective abatement strategies, though substantial reductions remain necessary regardless of the method used. The authors argue that marginal abatement cost data for different gases and sectors is essential for evaluating the 2025 New York State Energy Plan.

The report critiques proposed rollbacks of US vehicle fuel economy and emissions standards by the DOT and EPA. It argues that the agencies incorrectly assume fuel efficiency improvements necessarily sacrifice vehicle performance, leading to an overestimation of costs to consumers. The author contends that many compliance pathways, such as turbocharging and electrification, can improve both efficiency and performance, and that reducing horsepower can provide public benefits by decreasing accident rates and infrastructure wear.

The report argues that federal agencies are bypassing legal responsibilities for reasoned decisionmaking to advance a deregulatory agenda. It details ten specific analytical requirements for proper regulatory repeals, including the necessity of considering both costs and benefits, accounting for indirect and non-monetized effects, and avoiding the use of outdated data or discredited models.

The document examines the health and economic impacts of per- and polyfluoroalkyl substances (PFAS), known as "forever chemicals," and advocates for a categorical regulatory approach. It highlights that current U.S. efforts, such as EPA drinking water limits, are insufficient because manufacturers can replace banned individual PFAS with other similar chemicals. The brief notes that annual health damages in the U.S. are estimated between $920.91 million and $62.6 billion across different studies, though these are likely underestimates. While cleanup technologies for water exist, those for soil and air remain undeveloped, making restrictions and bans the most cost-effective way to address ongoing contamination.

The Institute for Policy Integrity challenges the Fish and Wildlife Service's (FWS) proposal to remove the "blanket rule," which applies endangered species prohibitions to threatened species by default. The Institute asserts that the FWS's rationale is flawed because the D.C. Circuit Court of Appeals previously found the rule consistent with the statute and because recent Supreme Court decisions do not mandate the withdrawal of regulations upheld by prior judicial decisions.

The research argues that government models for offshore oil and gas leasing often underestimate climate impacts by assuming continued fossil fuel reliance and ignoring climate initiatives. Using the Bureau of Ocean Energy Management’s Market Simulation Model, the authors demonstrate that accounting for increased substitution between fossil fuels and renewables leads to more elastic energy demand and significantly higher projected net climate effects from leasing policies.

The document outlines expert perspectives on how climate damages exacerbate inequality and identifies three primary equity risks associated with carbon dioxide removal (CDR): moral hazard, the use of removed CO2 for enhanced oil recovery, and negative social or environmental impacts.

The paper introduces a residual demand hypersurface to better measure market power in locational pricing markets, specifically by analyzing how output changes at one location impact prices across all locations. This model is applied to the Italian electricity market to explain supplier bidding behavior and the effects of generation capacity divestment.

The Institute for Policy Integrity disputes a draft U.S. Department of Energy (DOE) report titled “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate,” which claims that climate impacts are too small to justify aggressive abatement. The Institute asserts that surveys of economic experts actually show a broad consensus that significant mitigation is warranted and that climate change will cause significant damage, including limited economic growth and increased mortality.

The report addresses the integrity problems inherent in carbon offsets, noting that no mechanism can entirely guarantee permanence or additionality. It proposes moving away from treating offsets as perfect and instead using an 'equivalence' concept to determine how many imperfect offsets equal one perfect offset based on carbon concentrations or warming potential. The author suggests that acknowledging these risks can prevent the abandonment of offsets that still provide value, such as delaying tipping points, provided that claims (like net-zero) are adjusted to reflect uncertainty and avoided damages.

The document challenges the common use of the term "baseload" as a justification for favoring specific energy resources, clarifying that "baseload" refers to the minimum constant load of an electric system rather than a specific type of power plant. It argues that describing certain resources as "baseload resources" does not prove they are the most cost-effective or reliable options for meeting that demand, nor does it guarantee grid security during peak demand. The brief aims to distinguish between "baseload," "dispatchable," and "firm" resources to counter rhetoric suggesting that retiring such resources inherently risks grid reliability.