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Public Comments
EPA Science Advisory Board Input
As part of EPA’s June 5-6 meeting of the Chartered Science Advisory Board (SAB), we submitted both oral and written input on several issues, including the Clean Water Rule, power-sector emissions of air toxics, vehicle emissions standards, and the Science Transparency Rule.
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Public Comments
Comments to Iowa Utilities Board on Energy Efficiency Program Benefits
The Iowa Utilities Board is currently reviewing its policies on energy efficiency planning. We submitted comments supporting some of the suggestions made by stakeholders to better gauge the benefits of the energy efficiency programs.
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Public Comments
Additional Comments to EPA and NHTSA on Vehicle Emissions Standards Economic Analysis
The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) are proposing to weaken key fuel economy and greenhouse gas emissions standards for future vehicle models. In October, we highlighted our concerns with some of the economic analysis supporting the proposal. The Alliance of Automobile Manufacturers submitted comments that included economic analysis supporting the proposed rule prepared by NERA Economic Consulting and Trinity Consultants. In December, we wrote supplemental comments rebutting NERA and Trinity’s analysis, identifying serious flaws and unexplained departures from longstanding practices. NERA recently responded.
Our latest comments detail how NERA’s response does not address many of the problems we previously discussed. As our comments explain, the analysis relies on unreliable modeling and methodologies, for which NERA still has not provided critical details. NERA also misstates or fails to respond to our points on a number of topics, such as scrappage and fuel savings benefits. We point out the shortcomings in NERA’s response and provide more detail on each of the topics.
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Public Comments
Comments to BLM on Oil and Gas Lease Sales
We recently submitted comments to the Bureau of Land Management (BLM) about environmental assessments for three planned oil and gas lease sales in Oklahoma and New Mexico. BLM estimates and quantifies some direct, upstream, and downstream greenhouse gas emissions from the leasing plans, but fails to include a monetized estimate or meaningful assessment of the real-world climate damages those emissions will cause.
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Public Comments
Comments to DOE on Energy Conservation Standards for Small Motors
The Department of Energy called for input on developing and analyzing energy conservation standards for small electric motors. We submitted comments encouraging DOE to account for the monetized climate benefits of greenhouse gas emissions using social cost of carbon estimates.
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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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News
Testimony to New Jersey Legislature on Valuing Climate Impacts
Peter Howard and Denise Grab both provided testimony at an April 25 New Jersey State Legislature hearing on climate change mitigation and what the state can do to address greenhouse gas emissions. They discussed how New Jersey can contextualize and weigh climate impacts by using the social cost of greenhouse gases.
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Public Comments
Comments to BLM on Environmental Impacts of Federal Oil and Gas Leases
In response to a District Court order, the Bureau of Land Management (BLM) recently prepared a Supplemental Environmental Assessment (EA) for five federal oil and gas leasing decisions issued in 2015 and 2016. We submitted comments that focus on the agency’s failure to adequately quantify greenhouse gas emissions and monetize their climate impacts.
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Public Comments
Comments to EPA on Reconsideration of Mercury and Air Toxics Standards
The Environmental Protection Agency (EPA) is proposing to withdraw a prior finding that it is “appropriate and necessary” to regulate power-sector emissions of mercury and other “air toxics” under the Clean Air Act. We submitted comments arguing that EPA has failed to provide a reasoned explanation for this change of course.
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Public Comments
Comments on California Public Utilities Commission’s New Analysis Framework
We recently encouraged the California Public Utilities Commission (CPUC) to clarify aspects of its new process for evaluating the social costs and benefits of energy resources. As we discussed in prior comments, the proposed analysis framework, the Societal Cost Test (SCT), will help the Commission to make investments that provide the greatest welfare benefits. Our new comments ask CPUC to provide some additional information in the SCT proposal.
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