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Recent Projects

Viewing recent projects in Public Comments
  • Comments on New Jersey’s Energy Master Plan

    New Jersey’s 2019 Energy Master Plan (EMP) outlines how the state can achieve its emissions reduction target of 80% below 2006 levels, as well as 100% clean energy, by 2050. We submitted comments applauding improvements to the draft EMP and making further suggestions. Our comments encourage the state to establish a technology-neutral policy framework to achieve its emissions reduction goal, compensate distributed energy resources in a way that reflects their full social value, and implement reforms to advance related technological and regulatory frameworks. We also submitted comments last October, during the EMP scoping phase, that made suggestions on grid resilience, rate design, and energy storage incentives.

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  • Petition to NHTSA for Reconsideration of Fuel Economy Penalties

    We filed a petition requesting that the National Highway Traffic Safety Administration (NHTSA) reconsider and rescind a new rule reducing penalties for automobile manufacturers that fail to meet corporate fuel economy standards. Our petition explains how NHTSA’s analysis ignores financial and environmental benefits forgone by the rule and relies on flawed, even contradictory evidence. NHTSA’s weakened fuel economy penalties deprive the public of substantial benefits and should be rescinded.

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  • Comments to Minnesota on Electric Resource Planning and the Social Cost of Carbon

    The Minnesota Pollution Control Agency and Minnesota Department of Commerce requested comments on their proposal to consider resource planning scenarios using a range of both environmental and regulatory costs. Minnesota has been a leader among states on incorporating environmental externalities into electricity policy, and our comments encourage the agencies to continue requiring the use of the social cost of carbon.

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  • Comments to CEQ on NEPA and Greenhouse Gas Emissions

    The Council on Environmental Quality is proposing to revise its National Environmental Policy Act guidance on the consideration of greenhouse gas emissions. We submitted comments explaining how the draft guidance makes vague and misleading statements with respect to when and how agencies must analyze the greenhouse gas emissions associated with their project approvals. We encourage CEQ to correct errors and align the guidance with federal caselaw and existing regulations.

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  • Comments to DOE on Grid Resilience

    The Department of Energy requested input on how it can enhance the resilience of electric infrastructure systems against severe weather events. We submitted comments, attaching our report on grid resilience and highlighting key takeways that may support DOE efforts to improve the power system.

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  • Comments to DOE on Energy Conservation Standards for Air Conditioners

    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 on Connecticut’s Proposed Value Categories for Distributed Energy Resources

    The Connecticut Department of Energy and Environmental Protection (DEEP) and Public Utilities Regulatory Authority (PURA) have proposed several quantitative and qualitative value categories it intends to examine in its study of the value of DERs. We submitted comments supporting their inclusion of avoided emissions costs, which covers both greenhouse gas emissions and ambient air pollutants, as a value category. We also encourage DEEP and PURA to include electricity system resilience among the quantifiable benefits of DER deployment.

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  • Comments to DOE on Energy Conservation Standards for Metal Halide Lamps

    The Department of Energy (DOE) recently asked for input on energy conservation standards for metal halide lamp fixtures. We submitted comments encourage DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.

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  • Joint Comments to BLM on Buffalo and Miles City Remand

    Following a ruling by the District of Montana, the Bureau of Land Management continued to decline to use the social cost of greenhouse gases in its anlysis of Buffalo and Miles City resource management plants. We submitted joint comments arguing that the agency should monetize the social cost of greenhouse gases on remand.

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  • Joint Comments to BLM on Vernon Well Pad Project

    The Bureau of Land Management's assessment of the Vernon Well Pad project, which would establish 32 new oil wells in Utah, fails to estimate resulting greenhouse gas emissions or monetize climate impacts. We submitted joint comments arguing that BLM to monetize the project's climate impacts using the social cost of greenhouse gases.

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