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Recent Projects

  • Court Filings

    Expert Declaration on Using the Social Cost of Carbon in Environmental Assessments

    May 25, 2018

    Fossil fuel development causes significant harm to the environment and human health, and our work continues to push for public disclosure of these harms. Dr. Peter Howard, our economics director, submitted a declaration on the environmental, public health, and social welfare costs of two resource management plans finalized in 2015 by the Bureau of Land Management (BLM) in Montana and Wyoming. Part of a suit against BLM by the Western Organization of Resource Councils, this declaration was presented alongside declarations from other noted climate experts, including Dr. James Hansen. Dr. Howard found that the air pollution and greenhouse gases emitted during the extraction, processing, transportation, and combustion of 11 billion tons of coal and oil and gas from thousands of wells at these two regions will cause more than $802 billion in damages between 2018 and 2028.

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  • Public Comments

    Comments to BOEM on Offshore Wind Program

    May 21, 2018

    The Bureau of Ocean Energy Management (BOEM) is responsible for leasing offshore areas for energy development, including areas for wind energy. The agency has so far awarded 13 commercial offshore wind leases, totaling about 17 GW of capacity. In response to its request for feedback on the future of its offshore wind program for the Atlantic Outer Continental Shelf, our comments to BOEM suggest steps toward developing a robust offshore wind program that will deliver benefits to the public for decades to come.

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  • Public Comments

    Comments on BLM’s Failure to Monetize Greenhouse Gas Emissions (Riley Ridge and Greater Mooses EISs)

    May 18, 2018

    We recently submitted two sets of joint comments to the Bureau of Land Management on the agency’s failure to monetize the climate effects of two fossil fuel projects in their NEPA analyses. Our comments explain why each of BLM’s reasons for not using the social cost of greenhouse gases in these NEPA assessments fails, and how the agency leaves the public and decisionmakers in the dark about the climate effects of the project, in violation of NEPA.

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  • Court Filings

    Brief on Department of Education’s Borrower Defense Rule

    May 11, 2018

    Under Secretary Betsy DeVos, the Department of Education has delayed implementation of the Borrower Defense Rule three times. This 2016 regulation was designed to help students who have been defrauded by for-profit educational institutions discharge their federal student loans. In our amicus brief to the U.S. District Court for the District of Columbia, we argue that the delays must be vacated because the Department failed to provide a reasoned explanation for any of them.

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  • Court Filings

    Brief on the Clean Water Rule’s “Applicability Date”

    May 11, 2018

    The Environmental Protection Agency and Army Corp of Engineers were sued for suspending implementation of the Clean Water Rule through the addition of an “applicability date” to the Clean Water Rule. Our brief to the U.S. District Court for the Southern District of New York in that case argues that the court should vacate the Suspension Rule because the agencies improperly ignored the forgone benefits of suspending the Clean Water Rule.

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  • Public Comments

    Comments to FERC on Electric Grid Resilience Order

    May 9, 2018

    The Federal Energy Regulatory Commission (FERC) requested feedback from regional electricity regulators on the state of resilience in wholesale markets, efforts underway to ensure grid resilience, and opportunities for future improvement. Their responses make clear that while grid resilience is an issue worthy of continued attention, there is not currently evidence to support mandatory, national or even regional action to address acute resilience concerns. Our comments to FERC argue that it should not seek a “one-size-fits-all” solution for all Regional Transmission Organizations and Independent System Operators (RTOs/ISOs), nor should it consider resilience a “catch-all” concept that opens the door to otherwise unsupported or unnecessary actions.

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  • Public Comments

    Comments to FERC on PJM Capacity Market Repricing Proposal

    May 7, 2018

    PJM Interconnection, L.L.C (PJM), a regional electricity transmission organization serving 13 states and Washington D.C., recently submitted a proposal to the federal government requesting changes that would “mitigate” the impact of state climate and energy policies on electricity markets. In our comments to the Federal Energy Regulation Commission (FERC), we argue that PJM’s proposals rest on a faulty premise that state public policies are distorting the economic efficiency of capacity market price signals, which heavily affect how generators enter and exit the market.

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  • Public Comments

    Comments to NHSTA on Civil Penalties for Violating Fuel Economy Standards

    May 2, 2018

    In December 2016, pursuant to the Inflation Adjustment Act of 2015, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that adjusted civil penalties for car manufacturers that violate fuel economy standards, in order to line them up better with inflation. That rule put the penalties at $14 per tenth of a mile per gallon. NHTSA is now proposing a new rule to lower the penalties from $14 per tenth of a mile per gallon back to the previous rate of $5.50 per tenth of a mile per gallon, claiming that the $14 penalty would have a significant negative economic impact. Our May 2018 comments argue that NHTSA should explain why it is justified in reducing the penalty from $14 to $5.50 and consider the forgone benefits when considering whether the civil penalties will have a “negative economic impact.” Because NHTSA has not provided this explanation, the proposed reduction is arbitrary and capricious.

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  • Policy Briefs

    Analyzing EPA’s Vehicle-Emissions Decisions

    May 1, 2018

    The Environmental Protection Agency sets greenhouse gas emissions standards for cars and light trucks, and it periodically reevaluates these standards to make sure that car manufacturers can comply. In April 2018, EPA withdrew its previous determination that standards for model year 2022–2025 vehicles were appropriate and would improve public welfare, now saying that more recent information suggests that the standards are too stringent.

    Our policy brief shows that EPA’s claim—that new information indicates that the assumptions underlying the previous determination are unrealistic—is not supported by the evidence. In fact, the opposite is the case. Recent trends in fuel prices, vehicle sales, automaker compliance, and safety all indicate that the existing 2022–2025 standards can be met at low cost while delivering large benefits to consumers and the economy. EPA’s decision to withdraw the standards will instead cause regulatory uncertainty that will hurt the automotive sector while also harming the environment.

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  • Public Comments

    Comments to EPA on Coal Combustion Residuals Rule

    April 30, 2018

    In 2015, the United States Environmental Protection Agency (EPA) established minimum criteria for the safe disposal of coal combustion residuals. At the time, EPA projected that the new rule would yield substantial health and environmental benefits. EPA now proposes to weaken the requirements of the 2015 rule but insists that doing so “will not change risks to human health and the environment” and thus will have no effect on the projected benefits of the 2015 rule. Our comments explain why EPA cannot reasonably assume that its proposed changes will have no effect on the 2015 rule’s projected benefits.

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