Recent Projects

The National Academy of Sciences (NAS) is currently conducting a review of the methodologies used to calculate the Social Cost of Carbon (SCC). We submitted comments to NAS to help inform this process.

As distributed energy resources (“DER”) are becoming increasingly common, the debate on how customers with such systems should be compensated is intensifying in many states. The National Association of Regulatory Utility Commissioners (NARUC) is creating a Distributed Energy Resources Compensation Manual to assist states with these policy decisions. We recently submitted comments to NARUC’s Staff Subcommittee on Rate Design regarding the most economically desirable approach to use for DER compensation.

The 2015 New York State Energy Plan set one of the most ambitious clean energy targets in the nation: 50 percent of all electricity used in the state should be generated by renewable energy sources. The Department of Public Service Staff recently released a White Paper on the Clean Energy Standard, with recommendations on how to achieve this ambitious goal. We submitted comments to the New York State Public Service Commission, outlining some additional steps that can help ensure that the Clean Energy Standard is not excessively costly, and is effective in achieving all of its policy goals.

We recently submitted two sets of public comments to the Bureau of Land Management (BLM) regarding a proposed rule to reduce waste of natural gas from venting, flaring, and leaks during oil and gas production on federal and Indian lands. BLM has proposed making natural gas lost through these processes subject to royalty payments.

We recently submitted comments to the New York Public Service Commission on how the Commission should develop an interim successor to its net metering policy, and how distributed energy resources should be valued in the future. We filed the comments jointly with the Environmental Defense Fund. To begin to move the retail electricity markets toward efficient and accurate recognition of the value of distributed energy resources, we suggest that the Commission should enhance its existing net energy metering policy to align compensation with the system benefits provided by distributed energy resources; establish a fully unbundled retail price structure; and specifically account for the environmental benefits of distributed energy resources in future pricing structures.

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.