Recent Projects

The Environmental Protection Agency (EPA) is proposing to withdraw a prior finding that it is “appropriate and necessary” to regulate power-sector emissions of mercury and other “air toxics” under the Clean Air Act. We submitted comments arguing that EPA has failed to provide a reasoned explanation for this change of course.

We recently encouraged the California Public Utilities Commission (CPUC) to clarify aspects of its new process for evaluating the social costs and benefits of energy resources. As we discussed in prior comments, the proposed analysis framework, the Societal Cost Test (SCT), will help the Commission to make investments that provide the greatest welfare benefits. Our new comments ask CPUC to provide some additional information in the SCT proposal.

The Environmental Protection Agency (EPA) and Army Corps of Engineers are proposing to replace the 2015 Clean Water Rule with a new rule that would harm many waterways by removing critical federal protections. We submitted comments detailing how the agencies provide flawed analysis in support of the proposal. Dr. Peter Howard and Dr. Jeffrey Shrader also submitted an expert report detailing the flaws in the agencies’ new valuation of wetland benefits.

The Department of Energy (DOE) recently issued a request for information on the energy conservation standards for direct heating equipment. We submitted comments that advise the Department to monetize climate benefits from greenhouse gas emissions reductions and discuss market-based approaches to energy conservation standards.

The Federal Communications Commission (FCC) is seeking comments on economic approaches that might be feasible and effective in reducing the negative impacts of orbital debris in space. We submitted comments offering initial suggestions for what the Commission might consider in choosing a market-based regulation. We also recommend that any impact assessment of the regulation takes into account the full range of direct and indirect benefits.

The Environmental Protection Agency (EPA) recently proposed a significant weakening of greenhouse gas emissions standards for new coal-fired power plants. We submitted comments focusing on flaws in the proposal and accompanying regulatory impact analysis.

The Bureau of Land Management (BLM) recently prepared a Draft Environmental Impact Statement (DEIS) for an oil and gas leasing plan within the Arctic National Wildlife Refuge (ANWR) Coastal Plain. We submitted comments explaining how fossil fuel extraction in ANWR would pose serious threats to a delicate ecosystem and would contribute significantly to climate change. Our criticism of the DEIS focuses on the methodological flaws in BLM’s analysis and their failure to consider viable leasing alternatives.

New Jersey is proposing a new state carbon emissions trading program, which means it will rejoin the Regional Greenhouse Gas Initiative (RGGI). RGGI is a cooperative effort among northeastern states to reduce carbon emissions from the electric power sector through allowance trading. New Jersey previously left the initiative in 2011. RGGI expansion promises several benefits, such as improved market efficiency, increased competitiveness, and lower carbon reduction costs. We submitted comments to both RGGI and New Jersey on how to best reintegrate the state.

A new wholesale energy market policy proposal in New York could undermine market efficiency by limiting the compensation available for energy storage resources. The New York Independent System Operator (NYISO) recently submitted changes to its market rules to encourage energy storage, as required by an order from the Federal Energy Regulatory Commission (Order No. 841). The filing prevents energy storage resources from participating in the wholesale markets if they also participate in retail compensation programs. We submitted comments explaining how this participation barrier is inconsistent with FERC’s requirements and should be changed.

The Federal Energy Regulatory Commission (FERC) recently released an Environmental Assessment (EA) for the Adelphia Gateway Project. FERC quantifies nearly 90,000 tons per year of direct carbon dioxide-equivalent emissions, but offers no meaningful analysis of the pipeline’s climate impacts. We submitted joint comments urging FERC to better weigh the significance of project’s impacts using the social cost of greenhouse gases methodology.