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Recent Projects

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  • Public Comments

    Comments to Interior on San Juan Mine Lease Extension DEIS (New Mexico)

    July 9, 2018

    The Department of the Interior is proposing to extend leasing and operations at New Mexico’s San Juan mine by 15 years, producing up to 53 million additional tons of coal that will release 97.5 million tons of greenhouse gas emissions when combusted. In our comments to Interior on its draft environmental impact statement (DEIS) for the mine’s lease extension, we criticize Interior’s failure to fully account for the climate effects related to the project by monetizing the damage these emissions will cause. This refusal leaves the public and decisionmakers in the dark about the climate effects of the project, and is arbitrary given that the agency relies on the project’s monetized benefits to justify its action.

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  • Court Filings

    Brief on Repeal of Interior’s Valuation Rule

    June 25, 2018

    In 2016, the Department of the Interior’s Office of Natural Resources Revenue (ONRR) issued the Consolidated Federal Oil & Gas and Federal & Indian Coal Valuation Reform (Valuation Rule). The Valuation Rule sought to ensure that states and the federal government receive the full value of royalties due under the law for oil, gas, and coal extracted from public land. In 2017, ONRR abruptly reversed course and repealed the rule. State attorneys general have now sued ONRR over the repeal and filed a motion for summary judgment. In our brief supporting the plaintiffs, we argue that ONRR did not provide a reasoned explanation for repealing the Valuation Rule, both because ONRR fails to accurately assess the repeal’s economic impact and because ONRR fails to provide a reasoned explanation for its abrupt change in course.

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  • Public Comments

    Comments to BLM on Potential Oil and Gas Leasing in Arctic National Wildlife Refuge

    June 19, 2018

    As the Bureau of Land Management (BLM) considers opening Alaska’s Arctic National Wildlife Refuge for oil and gas leasing, pursuant to language in the 2017 Tax Act, our comments explain that development of oil and gas in the Arctic Coastal Plain would pose serious threats to this delicate, pristine ecosystem. In preparing an Environmental Impact Statement (“EIS”) for this potential lease sale, BLM must consider the many factors that weigh strongly against any leasing or development in the Refuge.

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  • Public Comments

    Comments to Interior’s Royalty Policy Committee

    June 6, 2018

    Our policy director, Jayni Hein, published a new op-ed in U.S. News & World Report on the Interior Department’s failure to protect the public interest in fossil fuel leasing decisions. In addition, she submitted the op-ed as public comments to Interior’s Royalty Policy Committee and gave verbal remarks at its meeting on June 6, 2018. Hein argues that Interior is required by law to earn “fair market value” for the use and development of public natural resources, and that providing royalty rate reductions and other undue concessions would inappropriately transfer public revenue to fossil fuel industry stakeholders.

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  • 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 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 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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  • Public Comments

    Comments on the Rescission of BLM’s Waste Prevention Rule

    April 23, 2018

    The Bureau of Land Management has proposed to rescind or revise its 2016 rule to limit methane emissions associated with natural gas production. The analysis for the original rule showed it to be hugely beneficial to the public, largely due to the avoided climate damages, for which BLM relied on the IWG’s Social Cost of Methane in the original analysis. Now, BLM has radically altered the analysis for the rule, claiming that the costs outweigh its benefits and the Bureau is justifying its decision to rescind or revise the rule based on this flawed rehashing of the effects, even though many of the problematic elements actually undercut BLM’s justification of the proposal to rescind or revise the rule. We submitted comments focused on this faulty analysis and also submitted joint comments on how BLM failed to appropriately value the Social Cost of Methane and other foregone benefits that would result from the rule’s rescission.

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