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News
Fuel-Economy Standards, Corporate Penalties, and a Very Costly Rollback
The mistake of setting corporate fuel-economy penalties just a little too low can be magnified by automakers’ decisions to produce millions of cars with worse fuel-economy. And the Trump penalty appears to be way too low to motivate compliance. Here’s a breakdown of the reduced penalty and how it will likely affect cars, consumers, and our climate.
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Public Comments
Comments on Connecticut’s Study of the Value of Distributed Energy Resources
Connecticut’s Department of Energy and Environmental Protection (DEEP) and Public Utilities Regulatory Authority (PURA) are conducting a study to determine how it can best compensate distributed energy resources, like solar panels and residential battery installations, which can provide provide significant value to the grid. DEEP and PURA’s study involves an electric system dispatch simulation model and various DER technology use cases. We submitted comments on the model’s outputs and how they can be improved to better serve the study.
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Public Comments
Comments to BLM on Oil and Gas Lease Sale in New Mexico
The Pecos District Office of the Bureau of Land Management (BLM) released an environmental assessment of a 2020 oil and gas lease sale in New Mexico. Despite calculating that foreseeable leasing activities would produce over 28 millions tons of downstream CO2-equivalent over a 20-year time horizon, BLM fails to monetize the real-world impacts of those emissions. We submitted comments encouraging BLM to estimate climate impacts using social cost of carbon metrics.
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Public Comments
Comments to BLM on Alaska’s National Petroleum Reserve
The Bureau of Land Management’s (BLM) activity plan for the Alaska National Petroleum Reserve could lead to as much as 76.86 million tons of greenhouse gas emissions in a given year during peak production. We submitted joint comments urging BLM to monetize and contextualize the climate impacts of its plan using social cost of carbon metrics.
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News
Our Work on State Zero-Emission Credits Programs
Several states have determined that ensuring the viability of zero-emission electricity generation from nuclear power is critical to mitigating the impacts of climate change especially in the short term while states work to meet aggressive new clean energy goals. Through comments and amicus briefs, we’ve been involved in those efforts in both New York and New Jersey.
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Court Filings
Amicus Brief on New Jersey’s Zero-Emissions Credits Program
In 2018, New Jersey established a Zero-Emissions Credits (ZECs) program, which provides subsidies to the state’s nuclear power plants for reducing carbon emissions in the energy sector. Our amicus brief explains how the Social Cost of Carbon is the best available estimate for valuing harms caused by carbon dioxide emissions. We also argue that the ZECs program should account for the benefits of avoided emissions both inside and outside of New Jersey.
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Public Comments
Comments to EPA on Water and Air Pollution Limitations from Electric Power Generation
The Environmental Protection Agency (EPA) proposed to weaken technology standards adopted in 2015 that act as crucial controls on effluent and emissions from electric power generation. Our comments focus on EPA’s flawed legal and economic justifications for the proposed rule, which contravenes the Clean Water Act, creates harmful incentives to delay compliance with guidelines, and relies on flawed cost-benefit analysis. We also submitted joint comments that detail how EPA severely undervalues the proposed rule’s climate costs and must monetize the full social cost of carbon using the best available data and methodologies.
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Public Comments
Comments to EPA’s Chartered Science Advisory Board
We submitted four comments in advance of the Environmental Protection Agency’s (EPA) January 2020 meeting of its Chartered Science Advisory Board (SAB).
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Reports
Look Before You Lease
While the Trump administration’s goal of “energy dominance” has increased the public lands available for oil and gas development, no effort has been made to modernize the leasing system, even in the face of climate change. Our report explains how option value—which accounts for the informational value gained by delaying leasing decisions—can and should be factored into the Bureau of Land Management’s land use planning processes. Accounting for option value at multiple stages of the land use planning process would significantly improve BLM’s public lands stewardship, better protect the environment, and regain some of the economic and strategic advantages it has ceded to private developers. The report also describes case studies where BLM’s failure to consider option value has led to costly litigation and missed opportunities.
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Public Comments
Comments to BLM on Proposed Farmington Drilling Projects
The Bureau of Land Management’s (BLM) Farmington Field Office in New Mexico released an addendum to its environmental assessment for eighty-six drilling applications. The addendum estimates that the projects, in total, would result in more than 483 million metric tons of carbon dioxide-equivalent over the lifetimes of the assessments. BLM’s analysis, however, fails to consider the climate impacts of these emissions, which would amount to more than $25 billion. Our comments ask that BLM provide monetized estimates of these real-world climate impacts using social cost of greenhouse gases metrics.
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