Recent Projects

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 NHTSA’s weakened fuel economy penalties deprive the public of substantial benefits and should be rescinded.

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.

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 We submitted comments explaining how the draft guidance makes vague and misleading statements with respect to when and how agencies must analyze the greenhouse gas emissions associated with their project approvals.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.

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.

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. 

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.

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.

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.

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.

The Department of Health and Human Services (HHS) recently proposed a rule that would narrow the scope of civil rights protections for patients under the Affordable Care Act. We submitted comments that focus on serious flaws in HHS’s regulatory impact analysis for the proposal, which ignores potentially substantial costs to patients and makes unsupported claims regarding the proposal’s benefits.