Recent Projects

The Environmental Protection Agency (EPA) requested input on policy approaches to promote market-based programs that will improve water quality. We submitted comments suggesting that EPA provides additional clarity, works to avoid undermining key permitting goals, and considers using alternate market-based structures before reissuing its proposals.

The Colorado Public Utilities Commission is evaluating different options for electric utility participation in centralized electricity markets, as part of the Colorado Transmission Coordination Act. We submitted comments encouraging the Commission to move the state to a centralized market, which would help accomplish energy goals and would benefit generators, utilities, and customers.

We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.

The Department of Energy (DOE) made an initial determination that energy conservation standards for general service incandescent lamps do not need to be amended, even though improved efficiency is technologically feasible and a new standard would save consumers billions of dollars. We submitted comments detailing the flaws of DOE’s economic justification for its proposed decision.

The Massachusetts Department of Energy Resources is adopting a program that incentivizes the adoption of energy storage resources with the aim of displacing high-pollution resources during peak periods of energy use. We submitted comments that explain potential risks of energy storage integration and encourage Massachusetts to adjust its clean peak policies to maximize the emissions reduction potential of the state’s energy storage resources.

The Bureau of Land Management (BLM) released its environmental impact analysis of the Willow Master Development Plan, estimating the project will produce more than 260 million metric tons of greenhouse gas emissions. We submitted joint comments asking BLM to monetize the real-world climate effects of those emissions using the social cost of greenhouse gases.

The Environmental Protection Agency (EPA) is proposing to regulate four chemicals that have serious environmental and health risks. We submitted comments supporting EPA and suggesting ways the agency can strengthen its proposal and, additionally, urging EPA to reexamine its decision not to regulate a fifth chemical.

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

The Federal Motor Carrier Safety Administration (FMCSA) is proposing to revise duty length regulations for drivers of commercial motor vehicles. We submitted comments focusing on how FMCSA can improve its analysis of costs and benefits to social welfare and driver health.

The Colorado Public Utilities Commission (CPUC) proposed rule revisions to a recent clean energy bill, providing more information on how social cost of greenhouse gases (SCGG) estimates will be used. We submitted comments encouraging best practices for SCGG application that will help CPUC monetize climate externalities and weigh the costs and benefits of various decisions.