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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 FERC on the East Lateral XPress Project
The East Lateral XPress Project could result in the emission of over 3.6 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.
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Comments to FERC on Climate Risks, Reliability, and Resilience
The Federal Energy Regulatory Commission requested responses to a number of questions on the effects of climate change and electric system reliability. We submitted comments highlighting opportunitites to improve reliability and resilience by adjusting approaches the Commission and others take to planning, investing in, and operating grid components.
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Comments to ACUS on Periodic Review of Agency Regulation
The Committee on Regulation of the Administrative Conference of the United States requested input on best practices for agencies in undertaking periodic review of their existing regulations. We submitted comments providing a number of recommendations.
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Comments to ACUS on Regulatory Alternatives
The Committee on Regulation of the Administrative Conference of the United States requested input on how agencies should solicit public input on alternatives to rules under consideration. We submitted comments providing a number of recommendations.
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Comments to USPS on Purchase of Delivery Vehicles
The United States Postal Service (USPS) announced that it will prepare an environmental impact statement for the purchase of a mix of gas-powered and electrict delivery vehicles. We submitted comments on how the USPS can incorporate climate impacts into its review by using the social cost of greenhouse gases. We also urge the USPS to consider the alternative of an all zero-emission fleet.
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Comments on New York PSC’s Initial Report on Power Grid Study
The New York Public Service Commission (PSC) requested input on its initial report on the New York Power Grid Study. Our comments recommend steps the PSC can take to not only achieve emissions reduction goals, but also give appropriate priority to environmental justice.
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Comments to FERC on East 300 Upgrade Project
The East 300 Upgrade Project could result in the emission of over 2.3 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.
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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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Comments to DOE on Future Energy Conservation Rulemakings
The Department of Energy called for input on its prioritization process for energy conservation rulemakings. We submitted comments detailing immediate, mid-term, and long-term actions that DOE can take to more efficiently set energy conservation standards and deliver greater benefits to consumers, public health, and the environment.
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