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Recent Projects

Viewing recent projects in Natural Resources
  • Broadening the Use of the Social Cost of Greenhouse Gases in Federal Policy Cover

    Broadening the Use of the Social Cost of Greenhouse Gases in Federal Policy

    Our report highlights numerous areas in which the federal government should apply the social cost of greenhouse gases beyond regulatory cost-benefit analysis. It is organized under the framework of “decision-making, budgeting, and procurement” laid out in the President’s executive order, identifying a number of relevant actions—like environmental reviews conducted under NEPA and the assessment of royalty rates for federal land-management. In short, application of the social cost of greenhouse gases would be extremely beneficial for any executive branch decision with significant greenhouse gas implications.

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  • Comments to FERC on Natural Gas Infrastructure

    The Federal Energy Regulatory Commission (FERC) issued a notice of inquiry on how to revise its policy on certifying the construction and operation of interstate natural gas transportation facilities. We submitted comments providing numerous recommendations for how FERC can improve its evaluation of environmental impacts and methodology for determining whether there is need for a proposed project.

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  • Department of Interior Delays, Reassesses Trump-Era Rule on Fossil Fuel Royalty Rates

    The Department of Interior delayed the effective date of a Trump-era rule that lowers the royalty burden on corporations extracting fossil fuels on public lands. We provided significant input on the review of the rule, helping guide ONRR’s decision to delay the rule and further examine its legality and impact.

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  • Comments on Interior’s Review of Oil and Gas Program

    The Department of the Interior is conducting a review of its federal oil and gas leasing program. We submitted comments encouraging the Interior to pursue concurrent action on three fronts.

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  • Comments to FERC on the East Lateral XPress Project

    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 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. 

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  • Comments to FERC on East 300 Upgrade Project

    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. 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. 

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  • Comments to ONRR on Royalty Rates for Oil and Gas Leasing

    A new rulemaking by the Office of Natural Resources Revenue (ONRR) delays the effective date of its previously-finalized Valuation Reform and Civil Penalty Rule and seeks input on several questions. We submitted comments focusing primarily on a question about the role of climate impacts in setting royalty policy.

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  • Amicus Brief in D.C. Circuit on Methane Limits for Oil and Gas Sector

    The Environmental Protection Agency (EPA) recently finalized revisions to New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector. We filed an amicus brief in the U.S. Court of Appeals for the D.C. Circuit, focusing on EPA's flawed legal and economic justifications for the rule. 

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  • Comments to ONRR on Its New Proposal to Roll Back the Valuation Rule

    ONRR has proposed to roll back large portions of the Valuation Rule, after previously failing in court to both suspend the rule and repeal the rule.  We submitted comments explaining that the agency has failed yet again to provide a reasoned explanation for the rollback. 

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  • Amicus Brief in Ninth Circuit on Montana Coal Mine Expansion

    The expansion of the Bull Mountains Mine project in Montana would allow for an increase in coal production likely resulting in more than $9 billion in climate damages. We filed an amicus brief in the U.S. Court of Appeals for the Ninth Circuit criticizing the Office of Surface Mining’s analysis of the project, which fails to monetize climate impacts using the social cost of carbon. We explain that the project’s full economic benefit is, at most, just one-third of its expected climate costs. 

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