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Viewing recent projects in Public Comments
  • Comments to EPA on Delay of Emissions Rule for Wood Heaters

    The Environmental Protection Agency (EPA) is proposing to amend the 2015 New Source Performance Standards (NSPS) for residential wood heating devices, purporting to respond to retailer needs in the wake of the COVID-19 pandemic. Our comments detail how how the proposal contradicts the Clean Air Act’s mandate and longstanding agency guidance. The proposed rule will, even under the agencies’ own analysis, cause net harms to the public without providing any reasonable justification.

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  • Comments to FERC on Transmission Incentives

    The Federal Energy Regulatory Commission proposed changes to its electric transmission incentives, which aim to spur the deployment of technologies that enhance reliability, efficiency, and capacity of transmission facilities. We submitted comments identifying significant problems with the proposal, including its reliance on a benefit-cost ratio for project selection.

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  • Comments on Oklahoma’s Medicaid Waiver

    The Oklahoma Health Care Authority has requested permission from the U.S. Department of Health and Human Services to change the state’s Medicaid program in a variety of ways—including by introducing work requirements and premium payments for some beneficiaries. We filed comments opposing the request and explaining why the benefits, if any, of work and cost-sharing requirements are unlikely to justify the accompanying health and administrative costs.

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  • Comments to FERC on Middlesex Extension Natural Gas Project

    We submitted comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Middlesex Extension Project in New Jersey. FERC failed to provide a meaningful analysis of the pipeline facilities' climate effects.

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  • Comments to FERC on NERA Net Metering Petition

    The New England Ratepayers Association (NERA) recently petitioned the Federal Energy Regulatory Commission (FERC) to effectively overturn net metering policies nationwide. While FERC has previously and definitively answered the jurisdictional question concerning net metering, NERA asserts without evidence that controversy persists. We submitted comments describing the flaws of NERA’s argument and urging FERC to reject the petition.

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  • Comments to HHS on Blood Donation Policies

    The Department of Health and Human Services (HHS) asked for public input on a forthcoming report to Congress regarding strategies for ensuring an adequate blood supply during public health emergencies. Our comments recommended that the report endorse elimination of the Food and Drug Administration’s deferral policy for donations from men who have sex with men. The policy, which bars gay and bisexual men from donating blood for three months from the date of their last sexual contact, relies on outdated science regarding HIV transmission risk, stigmatizes gay and bisexual men, and increases the likelihood of blood shortages.

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  • Comments to Oregon PUC on the Social Cost of Carbon

    Oregon Governor Kate Brown signed an executive order directing state agencies, including the Public Utilities Commission (PUC), to reduce greenhouse gas emissions. We submitted comments encouraging the PUC to use Social Cost of Carbon metrics to monetize the benefits of avoided greenhouse gas emissions.

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  • Comments to BLM on Royal Gorge Oil and Gas Lease Sale

    The Bureau of Land Management (BLM) released its environmental assessment of a September 2020 lease sale in the Royal Gorge Field Office region of Colorado. We submitted comments asking BLM to monetize the real-world climate impacts of projected emissions using the social cost of greenhouse gases.

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  • Comments to DOE on Energy Conservation Standards for Air Conditioning and Heating Equipment

    The Department of Energy requested input on impact and emissions analysis for upcoming energy conservation standards. We submitted comments encouraging DOE to continue to monetize the full climate benefits of greenhouse gas emissions reductions. 

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  • Comments to DOE on Energy Conservation Standards for Water Source Heat Pumps

    The Department of Energy requested input on impact and emissions analysis for upcoming energy conservation standards. We submitted comments encouraging DOE to continue to monetize the full climate benefits of greenhouse gas emissions reductions. 

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