Recent Projects

Following a ruling by the District of Montana, the Bureau of Land Management continued to decline to use the social cost of greenhouse gases in its anlysis of Buffalo and Miles City resource management plants. We submitted joint comments arguing that the agency should monetize the social cost of greenhouse gases on remand.

The Bureau of Land Management's assessment of the Vernon Well Pad project, which would establish 32 new oil wells in Utah, fails to estimate resulting greenhouse gas emissions or monetize climate impacts. We submitted joint comments arguing that BLM to monetize the project's climate impacts using the social cost of greenhouse gases.

The Department of Health and Human Services (HHS) recently proposed a rule that would narrow the scope of civil rights protections for patients under the Affordable Care Act. We submitted comments that focus on serious flaws in HHS’s regulatory impact analysis for the proposal, which ignores potentially substantial costs to patients and makes unsupported claims regarding the proposal’s benefits.

The Department of Energy (DOE) recently proposed changes to its process for prescribing energy conservation standards for consumer products and commercial/industrial equipment. We submitted comments explaining how DOE’s proposed energy savings thresholds and consumer test are unjustified and will reduce important consumer and environmental benefits.

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.