Recent Projects

The PennEast 2020 Amendment Project, which provides for various additions to the proposed PennEast pipeline, would result in significant greenhouse gas emissions. We submitted comments on the Federal Energy Regulatory Commissions’s draft environmental assessment of the project, which fails to meaningfully assess the impact of emissions using social cost of carbon metrics.  

The Brattle Group developed a resource adequacy scenario analysis for the New York Public Service Commission (PSC), which is considering how to best meet its electricity generating capacity and resource adequacy needs. We submitted comments encouraging the PSC to consider several questions that Brattle’s analysis does not examine in depth.

The Environmental Protection Agency (EPA) finalized a rule delaying compliance deadlines for methane emissions controls at solid waste landfills. We filed a brief in the U.S. Court of Appeals for the D.C. Circuit focusing on EPA's failure to adequately assess the forgone benefits of the delay.

The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. We submitted comments encouraging BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. We also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal. 

The Environmental Protection Agency (EPA) proposed a rule adjusting the test procedures to calculate greenhouse gas emissions and fuel economy rates for the GHG and CAFE programs and the Fuel Economy and Environment Label upon adoption of Tier 3 certification test fuel. We submitted comments that encourage EPA to finalize the proposal, and explain that EPA would be required to provide a new proposal, rationale, and analysis if it chooses to forgo the GHG emissions test adustment. 

We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.

If constructed, the Tennessee pipeline extension and related projects would be responsible for substantial greenhouse gas emissions. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to quantify the project’s emissions and monetize climate damages using Social Cost of Carbon estimates is arbitrary.

In 2022, New Mexico’s largest utility company will retire the San Juan Generating Station, a coal-burning power plant that has operated since 1973. In light of the decision, the state’s Public Regulatory Commission (PRC) has adopted a plan to replace the plant’s power output with 100 percent renewable energy and battery storage. The plan is a significant victory for the community groups and environmental advocates that have pushed to expedite the clean energy transition, and our efforts helped pave the way for this decision.