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Viewing recent projects in Natural Resources
  • Comments to FERC on Marcus Hook Project

    The Federal Energy Regulatory Commission has granted the Marcus Hook Compression Project Limited Notice to Proceed with the first phase of construction activities, which is currently underway. Our recent comments on FERC's draft environmental impact statement for the project recommend that the agency improve its consideration of climate impacts. It can do so by quantifying upstream emissions, assessing the project’s incremental climate harms, and considering avenues to mitigate its greenhouse gas contributions.

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  • Comments to FERC on LNG Compression Project in New York

    Iroquois Gas Transmission System’s Enhancement by Compression Project would provide a significant increase in natural gas compression and transportation, potentially resulting in over 2.4 million metric tons in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. We submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

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  • Toward Rationality in Oil and Gas Leasing Cover

    Toward Rationality in Oil and Gas Leasing

    Building the Toolkit for Programmatic Reforms

    Leasing public lands and waters for fossil-fuel extraction drives a quarter of U.S. carbon dioxide emissions. Our new report offers analytic tools for federal leasing decisions to drive policies that maximize economic and environmental welfare—nationally and locally.

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  • 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 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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