Recent Projects

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.

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.

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.

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.

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.

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.

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.

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.

The Department of the Army proposed a rule that would have the agency quantify the greenhouse gas emissions of significant actions but does not require impacts to be assessed using the social cost of carbon. We submitted comments urging the Army to not adopt the provision. Its environmental analyses should consider monetized climate impacts.

The National Highway Traffic Safety Administration's interim final rule delays the application of its 2016 inflation adjustment of the penalty for violating the corpoate average fuel-economy (CAFE) standards. We submitted comments explaining that the rule is untimely under the Inflation Adjustment Act, whose deadlines to amend the intial catch-up inflation adjustment expired years ago.