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  • Comments on Proposed Offshore Leasing Program for 2017-2022

    We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values.

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  • The Bureau of Land Management's Modeling Choice for the Federal Coal Programmatic Review Cover

    The Bureau of Land Management’s Modeling Choice for the Federal Coal Programmatic Review

    There are multiple power sector models available to the Department of Interior (DOI)’s Bureau of Land Management (BLM) for analyzing the effect of current and alternative coal regulations and leasing policies during preparation of its programmatic environmental impact statement (PEIS). This document lays out model selection criteria to assist BLM in weighing the benefits and costs of these available models, and offers recommendations for model selection, highlighting the tradeoff between model complexity and transparency.

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  • Comments on BLM Rule to Control Fugitive Methane Emissions

    We recently submitted two sets of public comments to the Bureau of Land Management (BLM) regarding a proposed rule to reduce waste of natural gas from venting, flaring, and leaks during oil and gas production on federal and Indian lands. BLM has proposed making natural gas lost through these processes subject to royalty payments.

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  • Jayni Hein Addresses IEL’s Annual Oil and Gas Conference

    On February 19th, our Policy Director, Jayni Hein, presented at the Institute for Energy Law’s Annual Oil and Gas Law Conference in Houston. Speaking on a panel titled “How Revenues Should be Collected for the Use of Federal Lands for Energy Development.”

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  • Brief for BLM Coal Lease Case

    We recently submitted an amicus brief in a case challenging two large coal leases approved by the Bureau of Land Management (BLM). The case, WildEarth Guardians v. U.S. Bureau of Land Management, is being heard by the U.S. Court of Appeals for the 10th Circuit. We believe that BLM used an irrational assumption about coal supply and demand in its environmental impact statement for the Wright Area coal leases in the Powder River Basin in Wyoming. Because of this flawed assumption, BLM’s presentation of the climate consequences of leasing, versus taking no action, is inaccurate and misleading, in violation of the National Environmental Policy Act (NEPA).

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  • Comments on the Forest Service’s Use of the Social Cost of Carbon

    In a proposed exception to the Colorado Roadless Rule, which provides for management of National Forest roadless areas where such activities as tree cutting and road construction are prohibited, the Forest Service analyzes the climate effects of its proposal. Though the agency’s choices to monetize greenhouse gas emissions and to use the Interagency Working Group’s estimates of the Social Cost of Carbon in its supplemental environmental impact statement are appropriate and necessary, its application of the metric is flawed in several respects.

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  • Struggling for Air Cover

    Struggling for Air

    Power Plants and the “War on Coal”

    Since the beginning of the Obama Administration, conservative politicians have railed against the President’s “War on Coal.” As evidence of this supposed siege, they point to a series of rules issued by the Environmental Protection Agency that aim to slash air pollution from the nation’s power sector. Because coal produces far more pollution than any other major energy source, these rules are expected to further reduce its already shrinking share of the electricity market in favor of cleaner options like natural gas and solar power. But the EPA’s policies are hardly the “unprecedented regulatory assault” that opponents make them out to be. Instead, they are merely the latest chapter in a multi-decade struggle to overcome a tragic flaw in our nation’s most important environmental law.

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  • Illuminating the Hidden Costs of Coal (Summary for Policymakers) Cover

    Illuminating the Hidden Costs of Coal (Summary for Policymakers)

    This summary document describes how the Department of the Interior can make strides in modernizing the federal coal program through straightforward royalty rate increases and fiscal reform.

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  • Illuminating the Hidden Costs of Coal Cover

    Illuminating the Hidden Costs of Coal

    How the Interior Department Can Use Economic Tools to Modernize the Federal Coal Program

    This report analyzes the hidden costs of coal production, and suggests updates that the Department of the Interior could make to modernize the federal coal program and earn “fair market value” for taxpayers, as required by law.

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  • Comments on Oil and Gas Methane Emission Standards

    We submitted public comments on the EPA on its proposed New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector.

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