Recent Projects

We recently submitted comments in response to the Food and Drug Administration’s (FDA) proposed rule to restrict the use of sunlamps used for artificial tanning. We concluded that although the proposed rule takes a significant step in reducing the risks of artificial tanning, the FDA should strengthen the justification for this proposed rule.

Concurrently with issuing its final Clean Power Plan to limit greenhouse gas emissions from existing power plants, the EPA issued a set of proposed federal plan requirements and model trading rules to provide states guidance as they determine their strategies to comply with the Clean Power Plan. We recently submitted comments to the agency on how these guidelines can be improved to best reduce compliance costs and promote effectiveness of the plan.

In a proposed exception to the Colorado Roadless Rule, which provides for management of National Forest roadless areas where such activities as tree cutting and road construction are prohibited, the Forest Service analyzes the climate effects of its proposal. Though the agency’s choices to monetize greenhouse gas emissions and to use the Interagency Working Group’s estimates of the Social Cost of Carbon in its supplemental environmental impact statement are appropriate and necessary, its application of the metric is flawed in several respects.

The Consumer Financial Protection Bureau (CFPB) is currently developing regulations that could protect millions of lower-income Americans from predatory payday lenders. We submitted public comments on the agency’s regulatory approach.

We submitted public comments on the EPA on its proposed New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector.

We recently submitted comments on New York State’s Reforming the Energy Vision (REV) initiative

We recently submitted two sets of comments to the EPA and National Highway Traffic Safety Administration on their greenhouse gas standards for trucks.

We recently submitted comments to the EPA regarding their endangerment finding and advance notice of proposed rulemaking on greenhouse gas emissions from aircraft.

We recently submitted comments to the District of Columbia Public Service commission (PSC) regarding their investigation of “technologies and policies that can modernize our energy delivery system.”

We recently submitted comments to the New York State Public Service Commission regarding the Reforming the Energy Vision (REV) initiative, which seeks to spur clean energy innovation and improve consumer choice and affordability in New York State. The Commission sought comments on how best to develop a cost-benefit analysis framework to evaluate utility proposals within the REV and related proceedings. Our comments addressed the consideration of externalities and the social cost of carbon in the Commission’s cost-benefit analysis.