Recent Projects

The Acadiana and Louisiana XPress projects could result in the emission of 31.9 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. We submitted comments encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions and weigh their climate impacts using the social cost of carbon. 

The FM100 and Leidy South projects in Pennsylvania could result in the emission of 17.6 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. 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. 

The Transportation and Climate Initiative called for public input on a Draft Memorandum of Understanding, which lays out a proposal for a Northeast and Mid-Atlantic regional program to establish a cap on carbon pollution from transportation and invest in further emissions reductions, cleaner fuels, and infrastructure. We submitted comments on the proposal suggesting that TCI adjust its definition of affected fuels, set the emissions cap to better reflect external damages from carbon emissions, implement the banking of allowances carefully, and verify that all offsets are real, permanent, and additional.

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.

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.

The Department of Energy requested input on its analysis of energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers. We submitted comments encouraging DOE to, as it has in the past, monetize the full climate benefits of greenhouse gas emission reductions.

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.

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.

We submitted four comments in advance of the Environmental Protection Agency’s (EPA) January 2020 meeting of its Chartered Science Advisory Board (SAB).