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Recent Projects

  • Public Comments

    Comments to the Colorado Public Utilities Commission on Electricity Rule Changes

    April 10, 2020

    The Colorado Public Utilities Commission is amending its rules relating to utilities, electric resource planning, and renewable energy standards. We submitted comments explaining why the Commission should use Social Cost of Greenhouse Gases estimates to monetize the externalities of carbon pollution. Our recommendations include rule revisions and new language that will help include monetized estimates of climate impacts in all relevant decisionmaking. We also submitted supplemental comments on additional rule revisions, building on our original comments to further describe how the Commission can best express and apply the Social Cost of Greenhouse Gases.

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  • News

    Key Economic Errors in the Clean Car Standards Rollback

    April 1, 2020

    The federal Clean Car Standards promised steadily increasing fuel efficiency and lower vehicle emissions. The National Highway Traffic Safety Administration and the Environmental Protection Agency have now rolled back those standards, eviscerating important public health benefits and fuel savings for consumers. But the agencies’ own analysis shows that the rollback will cause more harm than good for society. And even the slight benefits that the agencies find under certain assumptions are premised on a flawed economic analysis that is riddled with problems.

    We released a resource that explains the main economic problems with the rollback’s justification, identifying several critical errors and detailing how they invalidate the agencies' own claims

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  • Reports

    Carbon Pricing in Wholesale Electricity Markets

    March 25, 2020

    This report explains how carbon-pricing rules in organized wholesale electricity markets can improve economic efficiency. It then explores the economic principles and legal requirements for RTOs, states, and the Federal Energy Regulatory Commission to consider when implementing a carbon-pricing rule in organized wholesale electricity markets. And it identifies several policy-design approaches that, to varying degrees, meet those economic principles and are likely to be found legally permissible.

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  • Public Comments

    Comments to EPA on Federal Emissions Management from Oil and Gas Sources in Utah

    March 23, 2020

    The Environmental Protection Agency’s (EPA) Federal Implementation Plan (FIP) for managing emissions on the Uintah and Ouray Indian Reservation in Utah proposes control requirements for new, modified, and existing oil and natural gas sources. Despite forecasting that the requirements would lead to a substantial decrease in methane emissions, EPA severely underestimates resulting benefits through the use of an “interim” social cost of methane metric that disregards the best peer-reviewed science. We submitted joint comments detailing EPA’s failure to adequately monetize and evaluate the benefits of the FIP.

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  • Public Comments

    Comments to EPA on Lead and Copper Regulation Revisions

    March 23, 2020

    The Environmental Protection Agency (EPA) proposed revisions to the National Primary Drinking Water Regulation for lead and copper. Our comments ask EPA to more fully monetize the benefits and better assess the significance of non-monetized benefits of the proposal. We also submitted a letter to EPA’s Science Advisory Board (SAB) summarizing our comments and encouraging the SAB to consider our points during its review of the proposed revisions.

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  • Public Comments

    Comments to FMCSA on Commercial Driver Training Compliance Extension

    March 20, 2020

    The Federal Motor Carrier Safety Administration (FMCSA) proposed to extend the compliance dates of its entry-level commercial driver training program from 2020 to 2022. The program includes space and speed management training that reduces vehicle emissions. FMCSA projects that extending compliance dates would forgo hundreds of thousands of metric tons of greenhouse gas emissions. We submitted joint comments criticizing the agency’s regulatory impact analysis, which vastly underestimates forgone benefits and relies on flawed ‘interim values’ of the social cost of carbon.

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  • Climate Damages of U.S. LNG Exports

    March 20, 2020

    Our resource compiles the greenhouse gas emissions and resulting damages from liquefied natural gas (LNG) export terminals.

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  • Public Comments

    Comments to HUD on Fair Housing Rule

    March 16, 2020

    The Department of Housing and Urban Development (HUD) has proposed to repeal and replace the 2015 Affirmatively Furthering Fair Housing rule, which sought to improve the process by which state and local governments that receive HUD funding identify and mitigate impediments to fair housing in their communities. We submitted comments detailing deficiencies in the Department’s regulatory impact analysis for the proposal. Specifically, we explain how HUD (1) ignores benefits of the 2015 rule that will be forgone under the proposed replacement, and (2) overestimates cost savings that will result from the proposed replacement.

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  • Public Comments

    Comments to CEQ on the National Environmental Policy Act

    March 10, 2020

    The Council on Environmental Quality (CEQ) proposed changes to the regulations implementing the National Environmental Policy Act (NEPA), a decades-old statute that requires federal agencies to analyze the environmental impact of actions. We submitted comments explaining how the proposed rule runs afoul of the statute, drastically limiting agencies’ abilities to consider various effects and implement NEPA procedures. We also submitted joint comments detailing how the provisions would undermine analysis of climate effects, and encouraging CEQ to promote the use of the social cost of greenhouse gases.

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  • Public Comments

    Comments on the Transportation and Climate Initiative

    February 28, 2020

    The Transportation and Climate Initiative called for public input on a Draft Memorandum of Understanding, which lays out a proposal for a Northeast and Mid-Atlantic regional program to establish a cap on carbon pollution from transportation and invest in further emissions reductions, cleaner fuels, and infrastructure. We submitted comments on the proposal suggesting that TCI adjust its definition of affected fuels, set the emissions cap to better reflect external damages from carbon emissions, implement the banking of allowances carefully, and verify that all offsets are real, permanent, and additional.

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