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Comments on Greenhouse Gas Emission Offsets from Rail Tie Wind Project
The Rail Tie Wind Project would offset approximately 900,000 metric tons of carbon dioxide emissions annually compared to typical U.S. electric generation. We submitted comments encouraging the Western Area Power Administration to provide context for those emission offsets by using the social cost of greenhouse gases.
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Comments to Maryland PSC on Energy Storage Report
The Maryland Public Service Commission requested input on its working group's energy storage report. We submitted comments in support of several of the working group's recommendations. We also encourage the Commission to apply the same principles that inform the report to assess the net emissions impacts of energy storage installations.
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Comments to New York PSC on Gas Planning Procedures
The New York Public Service Commission requested input on its Staff Gas System Planning Process Proposal. We submitted comments encouraging the Commission to add several minor requirements and directly address the legal tensions and ambigious policies that make planning decisions more challenging.
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Comments to FERC Following Technical Conference on Market Design
The Federal Energy Regulatory Commission (FERC) requested input on the expanded minimum offer price rule (Expanded MOPR) in the PJM capacity market, as well as prospective alternative approaches that could replace PJM's Expanded MOPR. We submitted comments addressing the questions posed while drawing attention to reforms that FERC should undertake.
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Comments on FERC’s Office of Public Participation
The Federal Regulatory Energy Commission (FERC) solicited comment from interested parties on how the Commission should structure their Office of Public Participation to facilitate public engagement. We submitted comments highlighting the potential benefits of public participation by environmental justice communities and identifying best practices that FERC’s Office of Public Participation (OPP) should adopt.
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Comments to Federal Finance Housing Agency on Climate Risk Disclosure
The Federal Housing Finance Agency requested information on the risks that climate change and natural disasters pose to the housing finance system. We submitted short comments and attached our report with the Environmental Defense Fund, Mandating Disclosure of Climate-Related Financial Risk, which surveys the variety of risks that U.S. corporations, including those in the housing sector, face from climate change’s physical effects and policy and market consequences.
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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 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.
Viewing recent projects in Public Comments