Recent Projects

The Putnam Expansion Project involves the construction and installation of natural gas infrastructure that will result in downstream emissions of approximately 3.26 million metric tons carbon dioxide-equivalent each year. Our comments to the Federal Energy Regulatory Commission (FERC) focus on its environmental assessment of the project, which provides unclear and inadequate analysis of the emissions and their climate impacts. We urge FERC to monetize climate damages by using social cost of greenhouse gas metrics.

The Department of Energy proposed to not increase the efficiency of fluorescent lamp ballasts. We submitted comments noting that DOE fails to analyze the forgone emissions reductions of its proposed determination.

Due to a significant buildout of offshore wind in the mid-Atlantic as a result of falling costs and state policy commitments, new offshore transmission will be required. However, the market rules for the nation’s largest electricity grid operator, PJM, currently provide no practical path for the development of open-access transmission to connect planned but not-yet-developed offshore wind generation. We submitted comments urging the Federal Energy Regulatory Commission to eliminate barriers to these projects, lowering transmission costs and ensuring just and reasonable rates.

The National Highway Traffic Safety Administration (NHTSA) recently finalized a rule that significantly reduces the penalties that automakers pay for violating the corporate average fuel economy (CAFE) standards. In reducing the penalty, NHTSA rolled back an adjustment that had been made to the penalty under the Inflation Act, a statute requiring agencies to adjust civil monetary penalties to account for decades of inflation. We submitted an amicus brief in the Court of Appeals for the Second Circuit focusing on NHTSA’s faulty economic justifications for the rule, arguing that this repeal was unlawful.

The Bureau of Land Management failed to estimate the climate impacts of leasing activity that would produce over 5 million tons of carbon dioxide-equivalent in downstream emissions on an annual basis. We submitted comments urging the agency to use the social cost of greenhouse gases in its environmental assessment. 

The Environmental Protection Agency (EPA) proposed revisions to New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector. We submitted comments focusing on EPA’s flawed legal and economic justifications for the rule.

We submitted comments on the U.S. Department of State’s supplemental environmental impact statement for the proposed Keystone XL Pipeline project. A federal district court ruled that the agency’s original impact analysis was inadequate, failing to take all relevant information into account when projecting that the pipeline would not affect total crude oil production. The Department’s new analysis projects that the pipeline will likely increase total crude oil production by only partially offsetting production that would have occurred elsewhere under a “no action” scenario, but irrationally fails to account for this substitution effect when projecting the pipeline’s economic benefits. Our comments argue that the Department continues to violate NEPA by its lopsided treatment of the pipeline’s costs and benefits, through not only its inconsistent treatment of substitution effects but also its failure to assess the pipeline’s climate-related impacts through monetization.

The Colorado Public Utilities Commission is evaluating different options for electric utility participation in centralized electricity markets, as part of the Colorado Transmission Coordination Act. We submitted comments encouraging the Commission to move the state to a centralized market, which would help accomplish energy goals and would benefit generators, utilities, and customers.