Recent Projects

The Department of Energy (DOE) proposed changes to the Process Rule for prescribing energy conservation standards. We submitted comments and additional comments explaining how certain proposed changes violate both DOE's statutory mandate and the principles of rational rulemaking. We emphasize that the significance of energy savings must be weighed by considering all important costs and benefits.

The Department of Energy (DOE) recently asked for input on energy conservation standards for certain electrical grid equipment. We submitted comments encouraging DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.

The Bureau of Land Management (BLM) released its environmental impact statement for the Moneta Divide Natural Gas and Oil Development Project, which would significantly expand well drilling in Wyoming. The project would be responsible for billions of tons of greenhouse gas emissions over its lifetime. We submitted comments explaining why BLM should use the social cost of greenhouse gases to monetize and weigh the plan’s climate impacts.

The Environmental Protection Agency (EPA) proposed to deny New York’s Clean Air Act Section 126 Petition seeking reductions in pollution from upwind sources that significantly impede the state’s attainment of ozone pollution standards. We submitted comments explaining how EPA’s justification for the decision is flawed.

Peter Howard and Jason Schwartz provided an expert report on Colorado’s Zero Emission Vehicle program, which will reduce millions of tons of greenhouse gas emissions annually. They demonstrate how the program’s climate benefits can be monetized and how those estimates can provide useful context for decisionmakers and the public.

The Department of Housing and Urban Development (HUD) recently proposed a rule that would deny housing assistance to some immigrant households. We submitted comments focusing on serious flaws in HUD’s analysis of the rule’s impacts.

We submitted joint comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Jordan Cove natural gas exports project in Oregon. FERC failed to provide a meaningful analysis of the pipeline’s climate effects.

In April, district courts in Washington State, Oregon, and California blocked a Trump administration rule that makes harmful changes to the federal funding of women’s health services. Those decisions were recently appealed in the U.S. Court of Appeals for the Ninth Circuit. We filed amicus briefs arguing that the preliminary injunctions should be affirmed.

We submitted joint comments on the Army Corps of Engineers’ environmental assessment of the Pebble Mine Project in southwest Alaska. The Corps quantifies greenhouse gas emissions from the project but fails to provide a monetized estimate of the climate damages those emissions will produce.

In February, the Food and Drug Administration (FDA) proposed a rule that would strengthen regulations for sunscreen products. We submitted comments explaining how FDA can improve its analysis of the rule’s impacts.