Recent Projects

In August 2021, DOE proposed to return to holding less-efficient gas furnaces to the same standard as other gas furnaces. We filed comments supporting the proposal, while cautioning DOE against making unnecessary statements that might hinder its ability in the future to set standards that would encourage consumers to switch from gas-fired appliances to electric appliances.

In the EA, BLM recycles the main Trump-era arguments that agencies used to justify their decision not to apply the social cost of greenhouse gases. In these comments, we draw BLM’s attention the proposed action's significant climate damages, amounting to between $114 million and $161 million over the lifetime of the planned wells.

In our comment letter, we call on the agency to substantially reform the coal program to adequately account for externalities and protect the public interest.

The Bureau of Land Management (BLM) recently issued a notice of intent to complete a Supplemental Environmental Impact Statement (EIS) for an oil and gas leasing plan within the Arctic National Wildlife Refuge (ANWR) Coastal Plain. We submitted comments explaining how BLM’s previous EIS fell short of the agency’s obligation to assess the effects of oil and gas leasing and to consider reasonable alternatives.

The Federal Energy Regulatory Commission requested responses to a number of questions on the effects of climate change and electric system reliability. In April 2021, we submitted comments highlighting opportunities to improve reliability and resilience by adjusting approaches the Commission and others take to planning, investing in, and operating grid components.

Then FERC, following a technical conference over the summer, requested further comments on a specific series of questions. In September 2021, we submitted joint comments describing process options and resources for conducting climate resilience planning, and emphasized how accounting for climate impacts is relevant to consumer costs.

We submitted comments on the Environmental Protection Agency’s (“EPA”) notice of proposed rulemaking, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. Our comment urged EPA to: select the regulatory alternative that will maximize net social welfare and promote distributional justice; rely on legislative and regulatory history to help justify its aproach to lead time; and improve its modeling to more fully capture benefits of stronger standards.

We also submitted joint comments with a coalition of other environmental groups on EPA's use of the social cost of carbon (SCC) in its proposed regulation, recommending that the agency expand its justification its discount rates and inclusion of global damages in the SCC, and affirm that the SCC is a lower bound of projected climate impacts.

In the aftermath of summer storms that resulted in widespread and prolonged power outages, Michigan's Public Service Commission requested comments on whether utilities should continue to rely exclusively on historical data when planning for extreme events. In comments filed jointly with the Sabin Center for Climate Change Law at Columbia Law School, and the Initiative for Climate Risk and Resilience Law, Policy Integrity suggested processes and tools that the Commission should direct utilities to use to identify and mitigate vulnerabilities to the impacts of extreme weather and climate change impacts more generally.

The National Highway Traffic Safety Administration ("NHTSA") sets corporate average fuel economy ("CAFE") standards for light-duty vehicles, and penalizes automobile manufacturers who fail to meet applicable standards. In January 2021, NHTSA issued an Interim Final Rule repealing the inflation-adjusted penalty increase for Model Years 2019-2021, which we commented was untimely and disregarded critical environmental harms. 

In August 2021, NHTSA proposed to rescind the Interim Final Rule. We filed comments supporting the proposal for complying with inflation-adjustment obligations, driving fuel savings, and reducing pollution.

We filed a comment letter with the Federal Energy Regulatory Commission (FERC) regarding their continued failures to meaningfully assess the climate impacts of natural gas infrastructure projects, this time regarding the Alberta Xpress Project DEIS. The project will contribute up to 3.31 million metric tons of carbon dioxide equivalent per year in operational and downstream emissions, and it could cause at least $3.33 billion in climate costs over the twenty-one-year precedent agreement underlying it.

We submitted comments to FERC today providing suggested topics for the first meeting of the joint federal-state task force on transmission. Our comments respond to a request for topics related to barriers inhibiting more efficient and effective transmission planning and deployment. We identify two barriers that the task force should discuss -- jurisdictional issues related to transmission siting and the lack of a standardized cost benefit analysis rubric for transmission projects.