Recent Projects

The North Baja XPress Project would provide a significant increase in natural gas compression and transportation, potentially resulting in 9.5 million metric tons or more in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. In October 2020, we submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

In our August 2021 follow up letter responding to FERC's draft environmental impact statement for the project, we note that the Commission has taken the helpful steps of quantifying direct and downstream emissions, but should still quantify upstream emissions, assess the project's incremental environmental harms, and consider avenues to mitigate emissions.

The East 300 Upgrade Project could result in the emission of over 2.3 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. In March, we submitted comments encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions and weigh its climate impacts using the social cost of carbon. In August, we followed up with a comment letter regarding the Commission's continued failures to meaningfully assess climate impacts in the project's Draft Environmental Impact Statement.

We submitted comments to the Federal Energy Regulatory Commission (FERC) encouraging the agency to accept PJM’s proposed changes to the Minimum Offer Price Rule, which recognizes that generation-based externality payment for clean electricity resources can be welfare-enhancing, and removes the artificial barrier to market entry for resources that receive payments under state climate policies created by the previous rule.

The East Lateral XPress Project could result in the emission of over 3.6 million tons of downstream emissions in carbon-dioxide equivalence per year from the combustion of natural gas. We submitted comments (April 2021) and a follow-up letter (August 2021) encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions, weigh its climate impacts using the social cost of carbon, and consider mitigation measures.

The Federal Energy Regulatory Commission has granted the Marcus Hook Compression Project Limited Notice to Proceed with the first phase of construction activities, which is currently underway. Our recent comments on FERC's draft environmental impact statement for the project recommend that the agency improve its consideration of climate impacts. It can do so by quantifying upstream emissions, assessing the project’s incremental climate harms, and considering avenues to mitigate its greenhouse gas contributions.

Iroquois Gas Transmission System’s Enhancement by Compression Project would provide a significant increase in natural gas compression and transportation, potentially resulting in over 2.4 million metric tons in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. We submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

The Department of Energy (DOE) has issued a notice of intent to prepare an environmental impact statement for energy conservation standards for manufactured housing. We submitted comments urging DOE to use the social cost of greenhouse gas metric whenever it analyzes the effects of greenhouse gas emissions, whether in a regulatory impact analysis, environmental impact statement, or other decisionmaking process.

Thte Tennessee Valley Authority (TVA) published a Notice of Intent regarding the Kingston Fossil Plant, discussing different alternatives for retiring and replacing fossil fuel-powered energy generation facilities. We submitted comments encouraging TVA to better contextualize the climate impacts of each alternative using the social cost of greenhouse gases.

The Environmental Protection Agency is reconsidering its withdrawal of a waiver of preemption for California’s zero emission vehicle mandate and greenhouse gas emission standards. We submitted comments supporting the rescission of the waiver withdrawal.