Recent Projects

The Department of Energy (DOE) proposed to change the way it selects energy efficiency standards by excluding certain efficiency levels as not "economically justified" on the grounds of effects to small businesses, market competition, or consumer convenience.The change, however, would allow DOE to irrationally and inconsistently give preference to whichever subset of economic impacts the agency wants to focus on in order to deem standards that otherwise achieve net benefits as instead being not economically justified. We submitted comments explaining how the proposal will not ensure consistent consideration of statutory factors.

The Council on Environmental Quality (CEQ) proposed changes to the regulations implementing the National Environmental Policy Act (NEPA), a decades-old statute that requires federal agencies to analyze the environmental impact of actions. We submitted comments explaining how the proposed rule runs afoul of the statute, drastically limiting agencies’ abilities to consider various effects and implement NEPA procedures. We also submitted joint comments detailing how the provisions would undermine analysis of climate effects, and encouraging CEQ to promote the use of the social cost of greenhouse gases.

The Acadiana and Louisiana XPress projects could result in the emission of 31.9 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. We submitted comments encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions and weigh their climate impacts using the social cost of carbon. 

The FM100 and Leidy South projects in Pennsylvania could result in the emission of 17.6 million tons of downstream emissions in carbon-dioxide equivalence per year from the combusion of natural gas. We submitted comments encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions and weigh its climate impacts using the social cost of carbon. 

The Transportation and Climate Initiative called for public input on a Draft Memorandum of Understanding, which lays out a proposal for a Northeast and Mid-Atlantic regional program to establish a cap on carbon pollution from transportation and invest in further emissions reductions, cleaner fuels, and infrastructure. We submitted comments on the proposal suggesting that TCI adjust its definition of affected fuels, set the emissions cap to better reflect external damages from carbon emissions, implement the banking of allowances carefully, and verify that all offsets are real, permanent, and additional.

The Office of Management and Budget (OMB) requested input on the possibility of including an estimate of the social cost of taxation, known as marginal excess tax burden (METB), in regulatory-cost accounting for transfer rules under Executive Order 13,771. We submitted comments responding to OMB claims and providing further information about METB.

The Office of Management and Budget (OMB) issues yearly reports on the benefits and costs of federal regulations. We submitted comments on its draft 2018, 2019, and 2020 reports, explaining how OMB can better provide policymakers and the public with essential information.

Connecticut’s Department of Energy and Environmental Protection (DEEP) and Public Utilities Regulatory Authority (PURA) are conducting a study to determine how it can best compensate distributed energy resources, like solar panels and residential battery installations, which can provide provide significant value to the grid. DEEP and PURA’s study involves an electric system dispatch simulation model and various DER technology use cases. We submitted comments on the model’s outputs and how they can be improved to better serve the study.

The Department of Energy requested input on its analysis of energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers. We submitted comments encouraging DOE to, as it has in the past, monetize the full climate benefits of greenhouse gas emission reductions.

The Pecos District Office of the Bureau of Land Management (BLM) released an environmental assessment of a 2020 oil and gas lease sale in New Mexico. Despite calculating that foreseeable leasing activities would produce over 28 millions tons of downstream CO2-equivalent over a 20-year time horizon, BLM fails to monetize the real-world impacts of those emissions. We submitted comments encouraging BLM to estimate climate impacts using social cost of carbon metrics.