Recent Projects

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.

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.

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.

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.