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 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 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.

Jason Schwartz and Denise Grab prepared a testimony for the New Mexico Public Regulation Commission regarding a proposal to retire the San Juan Generating Units, a coal-fired power plant in New Mexico. Their testimony details how applying Social Cost of Carbon metrics would allow the Commission to better monetize and contextualize the climate impacts of the proposal. Retiring the San Juan coal units would deliver billions of dollars in benefits to agricultural productivity, property values, and human health.

The Federal Energy Regulatory Commission's environmental assessment of the Alaska LNG project failed to provide a meaningful analysis of the pipeline project's climate effects. We submitted joint comments encouraging FERC to monetize the social cost of greenhouse gases in its Environmental Impact Statement.

We submitted joint comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Jordan Cove natural gas exports project in Oregon. FERC failed to provide a meaningful analysis of the pipeline’s climate effects.