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Public Comments
Comments to the Department of Labor on Tip Pooling
The Wage and Hour Division of the Department of Labor (DOL) is proposing to implement new tip regulations under the Fair Labor Standards Act. We submitted comments asking DOL to provide a more detailed explanation of the proposed rule and improve its underlying analysis.
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Public Comments
Comments to EPA on Methane Emissions from Oil and Gas Operations
The Environmental Protection Agency (EPA) proposed revisions to New Source Performance Standards from methane and volatile organic compound (VOC) emissions in the oil and gas sector. We submitted comments focusing on EPA’s flawed and legal economic justifications for the rule.
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Public Comments
Comments to the State Department on the Proposed Keystone XL Pipeline
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.
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Public Comments
Comments to EPA on Water Quality Trading Proposals
The Environmental Protection Agency (EPA) requested input on policy approaches to promote market-based programs that will improve water quality. We submitted comments suggesting that EPA provides additional clarity, works to avoid undermining key permitting goals, and considers using alternate market-based structures before reissuing its proposals.
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Public Comments
Comments to Colorado on Participation in Centralized Electricity Markets
The Colorado Public Utilities Commission is evaluating different options for electric utility participation in centralized electricity markets, as part of the Colorado Transmission Coordination Act. We submitted comments encouraging the Commission to move the state to a centralized market, which would help accomplish energy goals and would benefit generators, utilities, and customers.
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Public Comments
Comments to the New York Public Service Commission on Resource Adequacy
We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.
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Public Comments
Comments to DOE on Conservation Standards for General Service Lamps
The Department of Energy (DOE) made an initial determination that energy conservation standards for general service incandescent lamps do not need to be amended, even though improved efficiency is technologically feasible and a new standard would save consumers billions of dollars. We submitted comments detailing the flaws of DOE’s economic justification for its proposed decision.
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Public Comments
Comments to Massachusetts on Clean Peak Energy Standards
The Massachusetts Department of Energy Resources is adopting a program that incentivizes the adoption of energy storage resources with the aim of displacing high-pollution resources during peak periods of energy use. We submitted comments that explain potential risks of energy storage integration and encourage Massachusetts to adjust its clean peak policies to maximize the emissions reduction potential of the state’s energy storage resources.
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Public Comments
Comments to BLM on Willow Master Development Plan
The Bureau of Land Management (BLM) released its environmental impact analysis of the Willow Master Development Plan, estimating the project will produce more than 260 million metric tons of greenhouse gas emissions. We submitted joint comments asking BLM to monetize the real-world climate effects of those emissions using the social cost of greenhouse gases.
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Public Comments
Comments to EPA on TSCA Chemicals Regulation
The Environmental Protection Agency (EPA) is proposing to regulate four chemicals that have serious environmental and health risks. We submitted comments supporting EPA and suggesting ways the agency can strengthen its proposal and, additionally, urging EPA to reexamine its decision not to regulate a fifth chemical.
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