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Public Comments
Comments to EPA on Changes to New Source Review
We submitted comments to the Environmental Protection Agency (EPA) regarding changes to its New Source Review (NSR) applicability regulations. Our comments focus on EPA’s failure to perform a cost-benefit analysis for the proposed rule.
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Public Comments
Comments on New Jersey’s Energy Master Plan
New Jersey’s 2019 Energy Master Plan (EMP) outlines how the state can achieve its emissions reduction target of 80% below 2006 levels, as well as 100% clean energy, by 2050. We submitted comments applauding improvements to the draft EMP and making further suggestions. Our comments encourage the state to establish a technology-neutral policy framework to achieve its emissions reduction goal, compensate distributed energy resources in a way that reflects their full social value, and implement reforms to advance related technological and regulatory frameworks. We also submitted comments last October, during the EMP scoping phase, that made suggestions on grid resilience, rate design, and energy storage incentives.
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Public Comments
Petition to NHTSA for Reconsideration of Fuel Economy Penalties
We filed a petition requesting that the National Highway Traffic Safety Administration (NHTSA) reconsider and rescind a new rule reducing penalties for automobile manufacturers that fail to meet corporate fuel economy standards. Our petition explains how NHTSA’s analysis ignores financial and environmental benefits forgone by the rule and relies on flawed, even contradictory evidence. NHTSA’s weakened fuel economy penalties deprive the public of substantial benefits and should be rescinded.
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Public Comments
Comments on Proposed Process Changes for Setting Energy Conservation Standards
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.
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Public Comments
Comments to DOE on Energy Conservation Standards for Distribution Transformers
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.
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Public Comments
Expert Report on Colorado’s Zero Emission Vehicle Program
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.
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Public Comments
Comments to FERC on Jordan Cove Natural Gas Project
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.
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Court Filings
Amicus Brief on Repeal of Fracking Rule
In 2017, the Bureau of Land Management (BLM) repealed an Obama-era rule that tightens environmental regulations for fracking on public lands. We filed an amicus brief detailing BLM’s irrational analysis of the repeal, which erases the rule’s significant net benefits and flouts longstanding standard practices.
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Public Comments
Comments to the Army Corps of Engineers on the Pebble Mine Project
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.
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Court Filings
Amicus Brief on BLM’s Repeal of Waste Prevention Rule
Last year, the Bureau of Land Management (BLM) repealed its Waste Prevention Rule, undoing crucial regulations that reduce natural gas waste from venting, flaring, and leaks. We submitted an amicus brief focusing on the problematic aspects of the repeal: BLM’s false understanding of its role in waste prevention and its faulty analysis of climate impacts.
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