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Public Comments
Comments to EPA on Coal Combustion Residuals Rule
The Environmental Protection Agency (EPA) recently proposed to significantly weaken requirements for the disposal of coal combustion residuals from coal-fired power plants. We submitted comments focusing on inadequacies in EPA’s assessment of the rule’s costs and benefits.
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Public Comments
Comments to EPA on Changes to New Source Review
We submitted comments to the Environmental Protection Agency (EPA) regarding changes to its New Source Review (NSR) applicability regulations. Our comments focus on EPA’s failure to perform a cost-benefit analysis for the proposed rule.
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Public Comments
Comments on New Jersey’s Energy Master Plan
New Jersey’s 2019 Energy Master Plan (EMP) outlines how the state can achieve its emissions reduction target of 80% below 2006 levels, as well as 100% clean energy, by 2050. We submitted comments applauding improvements to the draft EMP and making further suggestions. Our comments encourage the state to establish a technology-neutral policy framework to achieve its emissions reduction goal, compensate distributed energy resources in a way that reflects their full social value, and implement reforms to advance related technological and regulatory frameworks. We also submitted comments last October, during the EMP scoping phase, that made suggestions on grid resilience, rate design, and energy storage incentives.
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Public Comments
Petition to NHTSA for Reconsideration of Fuel Economy Penalties
We filed a petition requesting that the National Highway Traffic Safety Administration (NHTSA) reconsider and rescind a new rule reducing penalties for automobile manufacturers that fail to meet corporate fuel economy standards. Our petition explains how NHTSA’s analysis ignores financial and environmental benefits forgone by the rule and relies on flawed, even contradictory evidence. NHTSA’s weakened fuel economy penalties deprive the public of substantial benefits and should be rescinded.
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Public Comments
Comments to HHS on Proposed Weakening of Healthcare Nondiscrimination Rule
The Department of Health and Human Services (HHS) recently proposed a rule that would narrow the scope of civil rights protections for patients under the Affordable Care Act. We submitted comments that focus on serious flaws in HHS’s regulatory impact analysis for the proposal, which ignores potentially substantial costs to patients and makes unsupported claims regarding the proposal’s benefits.
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Public Comments
Comments on Proposed Process Changes for Setting Energy Conservation Standards
The Department of Energy (DOE) recently proposed changes to its process for prescribing energy conservation standards for consumer products and commercial/industrial equipment. We submitted comments explaining how DOE’s proposed energy savings thresholds and consumer test are unjustified and will reduce important consumer and environmental benefits.
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Public Comments
Comments to DOE on Energy Conservation Standards for Distribution Transformers
The Department of Energy (DOE) recently asked for input on energy conservation standards for certain electrical grid equipment. We submitted comments encouraging DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.
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Public Comments
Expert Report on Colorado’s Zero Emission Vehicle Program
Peter Howard and Jason Schwartz provided an expert report on Colorado’s Zero Emission Vehicle program, which will reduce millions of tons of greenhouse gas emissions annually. They demonstrate how the program’s climate benefits can be monetized and how those estimates can provide useful context for decisionmakers and the public.
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Public Comments
Comments to HUD on Housing Assistance Restrictions for Immigrant Families
The Department of Housing and Urban Development (HUD) recently proposed a rule that would deny housing assistance to some immigrant households. We submitted comments focusing on serious flaws in HUD’s analysis of the rule’s impacts.
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Public Comments
Comments to FERC on Jordan Cove Natural Gas Project
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.
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