Recent Projects

Despite being ordered to provide a more thorough analysis of greenhouse gas emissions by a U.S. district court, the Bureau of Land Management (BLM) failed to adequately consider emissions from a number of oil and gas leases in Utah. We submitted comments recommending that BLM use the social cost of carbon to weigh climate impacts and, further, assess the option value of deferring lease sales to improve its land management decisions.

The Bureau of Land Management and the Bureau of Indian Affairs forecast that resource management in New Mexico's Farmington Mancos-Gallup region would produce more than 300 million metric tons of cumulative greenhouse gas emissions under their preferred alternative. Our joint comments explain that the agencies should better evaluate the proposal's climate impacts using the social cost of greenhouse gases. We also submitted comments focused on the agencies' obligation to conduct environmental justice analysis under Executive Order 12,898.

The Environmental Protection Agency (EPA) proposed airplane pollution standards that have no effect on emissions and require no technological improvements. EPA does analyze one scenario in the technical support for the proposal, however, that appears to have modest greenhouse gas emissions reduction effects. But the agency improperly monetizes and weighs those reductions. We submitted joint comments that detail flaws in EPA’s analysis and describe how the agency can correctly apply the social cost of carbon.

The Arizona Corporation Commission regularly requires that load serving entities (LSEs), which supply electricity to ratepayers, file plans with a 15-year time horizon disclosing environmental impacts from different resource mixes and how they will address those impacts. We submitted comments encouraging the Commission to ask that LSEs provide monetized estimates of the damages they expect to result from greenhouse gas emissions using the social cost of carbon.

The Fish and Wildlife Service (FWS) proposed amendments to its regulations for designating critical habitat. Several of FWS’s changes are inconsistent with the best practices for weighing the costs and benefits of agency action. We submitted comments explaining how the proposal is flawed in multiple ways and should not be finalized.

A rule proposed by the Department of Labor would limit the shareholder rights of Employee Retirement Income Security Act (ERISA) participants. The rule, in particular, would eliminate opportunities for ERISA fiduciaries to vote on Environmental, Social, and Governance (ESG) proposals that have long-term financial benefits for retirements plans. We worked with the Environmental Defense Fund to submit comments detailing the flaws of the Department’s rule.  

The Department of Energy (DOE) requested input on the analytical framework, models, and tools that it is using to evaluate potential standards for room air conditioners. In the technical support document, DOE departs from recent practice by proposing to focus on the domestic-only “interim” social cost of greenhouse gases estimates. We submitted joint comments recommending that DOE should, as it has in the past, continue to monetize the full climate benefits of greenhouse gas emissions reductions, using the best available estimates, which were derived by the Interagency Working Group on the Social Cost of Greenhouse Gases.

The PennEast 2020 Amendment Project, which provides for various additions to the proposed PennEast pipeline, would result in significant greenhouse gas emissions. We submitted comments on the Federal Energy Regulatory Commissions’s draft environmental assessment of the project, which fails to meaningfully assess the impact of emissions using social cost of carbon metrics.  

The Department of Energy (DOE) recently requested input on its Energy Storage Grand Challenge, which is a program aimed at expanding the development and proliferation of energy storage systems in the U.S. electric power system. We submitted comments explaining what tools and policies are necessary to ensure that energy storage systems are accurately valued and can participate fully in the market.

The Environmental Protection Agency (EPA) proposed revisions to dust-lead post-abatement clearance levels. We submitted comments emphasizing how EPA, itself, concedes that the economic analysis supporting the rule is inaccurate.