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Recent Projects

Viewing recent projects in Natural Resources
  • Court Filings

    Amicus Brief on Repeal of Fracking Rule

    July 1, 2019

    In 2017, the Bureau of Land Management (BLM) repealed an Obama-era rule that tightens environmental regulations for fracking on public lands. We filed an amicus brief detailing BLM’s irrational analysis of the repeal, which erases the rule’s significant net benefits and flouts longstanding standard practices.

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  • Public Comments

    Comments to the Army Corps of Engineers on the Pebble Mine Project

    July 1, 2019

    We submitted joint comments on the Army Corps of Engineers’ environmental assessment of the Pebble Mine Project in southwest Alaska. The Corps quantifies greenhouse gas emissions from the project but fails to provide a monetized estimate of the climate damages those emissions will produce.

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  • Court Filings

    Amicus Brief on BLM’s Repeal of Waste Prevention Rule

    June 21, 2019

    Last year, the Bureau of Land Management (BLM) repealed its Waste Prevention Rule, undoing crucial regulations that reduce natural gas waste from venting, flaring, and leaks. We submitted an amicus brief focusing on the problematic aspects of the repeal: BLM’s false understanding of its role in waste prevention and its faulty analysis of climate impacts.

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  • Public Comments

    Comments on Caballo West Federal Coal Lease

    June 17, 2019

    The Office of Surface Mining and Reclamation Enforcement (OSM) issued its environmental assessment of extending the Caballo Mine West Tract federal coal lease. The mining plan would extend the life of the mine by approximately nine years, from 2042-2051, and increase the amount of coal mined from an average of 10.1 million tons per year to approximately 13.5 tons per year. Despite quantifying over 23 million tons of yearly carbon dioxide equivalent emissions, OSM does not include a monetized estimate of the climate damages those emissions will produce. We submitted joint comments asking that OSM use the social cost of greenhouse gases to better weigh the real-world impacts of potential coal leasing.

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  • Public Comments

    Comments to BLM on Evans McCurtain Oklahoma Coal Lease

    June 10, 2019

    The Bureau of Land Management (BLM) issued its environmental assessment of the Evans McCurtain coal lease in Oklahoma, which includes 3.28 million tons of recoverable coal. BLM quantifies around 9.6 million tons of carbon dioxide equivalent emissions from direct, upstream, and downstream sources over about eight years. The agency, however, does not provide a monetized estimate of the climate damages those emissions will produce. We submitted joint comments asking that BLM use the social cost of greenhouse gases to better weigh the real-world impacts of potential coal leasing.

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  • Public Comments

    Comments on BLM Coal Leasing Environmental Assessment

    June 10, 2019

    The Bureau of Land Management (BLM) recently issued an Environmental Assessment (EA) for its decision to lift the Obama administration’s pause on the federal coal leasing program. We submitted comments explaining how the EA provides flawed and incomplete analysis of BLM’s legal authority, alternatives to resuming leasing, and environmental effects.

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  • Public Comments

    Comments to BLM on Oil and Gas Lease Sales

    May 24, 2019

    We recently submitted comments to the Bureau of Land Management (BLM) about environmental assessments for three planned oil and gas lease sales in Oklahoma and New Mexico. BLM estimates and quantifies some direct, upstream, and downstream greenhouse gas emissions from the leasing plans, but fails to include a monetized estimate or meaningful assessment of the real-world climate damages those emissions will cause.

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  • Public Comments

    Comments to BLM on Environmental Impacts of Federal Oil and Gas Leases

    April 22, 2019

    In response to a District Court order, the Bureau of Land Management (BLM) recently prepared a Supplemental Environmental Assessment (EA) for five federal oil and gas leasing decisions issued in 2015 and 2016. We submitted comments that focus on the agency’s failure to adequately quantify greenhouse gas emissions and monetize their climate impacts.

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  • Court Filings

    Amicus Brief in Atlantic Coast Pipeline Case

    April 12, 2019

    If constructed, the Atlantic Coast Pipeline Project would be responsible for greenhouse gas emissions resulting in over $1.3 billion per year of climate damages. The Federal Energy Regulatory Commission’s (FERC) analysis estimates the quantity of the project’s emissions but does not analyze the context, intensity, or significance of the incremental climate damages they will cause. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to monetize the project’s climate damages using Social Cost of Carbon (SCC) estimates is arbitrary.

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  • News

    Court Overturns Repeal of Valuation Rule

    April 12, 2019

    The Institute for Policy Integrity helped contribute to a significant legal victory, as a federal district court in California today overturned the Trump administration’s repeal of the Interior Department’s Valuation Rule. The Valuation Rule sought to ensure that states and the federal government receive the full value of royalties due for oil, gas, and coal extracted from public lands. While the administration has lost numerous court cases related to deregulation, this is the first decision overturning a repeal of a rule. Policy Integrity submitted an amicus brief in the case and comments on the original rule and the repeal efforts.

    In our amicus brief, we argued that the repeal was unreasonable because of the agency’s inaccurate assessment of the repeal’s economic impact. District Judge Saundra Brown Armstrong’s opinion echoed some of the arguments from our brief and cited an academic article on deregulation written by Bethany Davis Noll and Denise Grab.

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