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Recent Projects

Viewing recent projects in Transparency
  • Public Comments

    Comments on Environmental Impact Statement for Changes to Bears Ears Monument

    November 15, 2018

    The Bureau of Land Management and U.S. Forest Service recently released a Draft Environmental Impact Statement (EIS) on their land management proposal for the Bears Ears National Monument. The EIS does not consider the environmental impacts of shrinking the monument’s boundaries. We submitted comments explaining why the agencies are responsible for providing detailed environmental analysis of their proposal to alter the Bears Ears planning area.

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  • Reports

    Deregulation Run Amok

    November 13, 2018

    Our report provides a survey of the legality of Trump Administration’s regulatory suspensions. Looking at a number of cases, we discuss the administration’s disregard for notice-and-comment requirements, statutory restrictions, and the reasoned explanation requirement. We also lay out some of the challenges facing advocates, and the strategies by which agencies have evaded review.

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  • Public Comments

    Comments on Carlsbad Region Fossil Fuel Leasing

    November 5, 2018

    We submitted two sets of comments to the Bureau of Land Management (BLM) in response to their Draft Resource Management Plan (RMP), which focuses on mineral development potential in the Carlsbad region of New Mexico. Our comments recommend that BLM not offer more lands for fossil fuel leasing, but instead consider alternatives with the greatest amount of conservation and wildlife protection. In particular, we focus on shortcomings in the RMP’s analysis and its failure to monetize climate damages.

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  • Public Comments

    Comments on Proposed Clean Power Plan Replacement

    October 31, 2018

    EPA recently issued a proposal to replace the Clean Power Plan (CPP) with a far weaker rule that will increase greenhouse gas and soot- and smog-forming emissions from the electric sector. Our comments explain why repealing the CPP is unnecessary, irrational, and harmful.

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  • Public Comments

    Comments on Proposed Weakening of Vehicle Emissions Standards

    October 26, 2018

    In August 2018, the Trump administration issued a proposal to dramatically weaken federal emissions standards for cars and light trucks, and to revoke the waiver that allows California to set its own standards. Federal emissions standards have been enormously successful at reducing greenhouse gas pollution and lowering fuel costs for consumers, and we recently submitted five separate sets of comments detailing the flaws with the Trump administration’s proposal.

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  • Public Comments

    Comments to EPA on Increasing Transparency in Cost-Benefit Analysis

    August 13, 2018

    Claiming an unsubstantiated need to improve consistency and transparency in its economic analyses, the Environmental Protection Agency (EPA) is considering revisions to how it weighs costs and benefits in rulemakings. In our comments to EPA, we argue that this proposal is searching for a problem that does not exist. In implying that the agency’s past analyses have somehow inappropriately considered costs and benefits, EPA relies on vague or false assumptions and misleading examples. In fact, through 2016, EPA’s past analyses of regulatory costs and benefits were among the most thorough, consistent, and transparent regulatory impact analyses conducted in the federal government and had justified some of the most net beneficial rules in the history of federal regulation.

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  • Public Comments

    Comments to Interior on Offshore Oil Well Control Revisions

    August 6, 2018

    After the Deepwater Horizon explosion and oil spill, the Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) issued regulations designed to improve the safety of offshore drilling operations. Finalized in 2016 after six years of extensive public involvement, these safeguards are now in the process of being rolled back by BSEE. Our comments to BSEE argue that it should not move forward with its notice of intent to repeal and/or modify the Blowout Preventer Systems and Well Control Rule, because BSEE has not provided a reasoned explanation for weakening and repealing safety requirements that it found necessary in 2016. BSEE must analyze all of the forgone societal benefits from rolling back the finalized safeguards, including safety and environmental risk reduction, time savings, industry cost savings, reduced fatalities, and lower externality costs.

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  • Public Comments

    Comments on FERC’s NOI on the Certification of Interstate Natural Gas Pipeline Facilities

    July 25, 2018

    In April 2018, the Federal Energy Regulatory Commission (FERC) issued a notice of inquiry on how to revise its policy on certifying the construction and operation of interstate natural gas transportation facilities. In the nineteen years since FERC’s existing policy statement was released, there have been significant advances in the understanding and measurement of climate change and other environmental effects of natural gas production, transportation, and consumption. Our comments suggest clarifications and improvements to FERC’s NEPA and Natural Gas Act analyses that will better inform policymakers and the public about the environmental effects of proposed projects. We also submitted joint comments on the appropriate use of the social cost of carbon in the interstate natural gas facilities certification processes, including why and how greenhouse gas emissions should be monetized in FERC’s NEPA and Natural Gas Act analyses.

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  • Public Comments

    Comments to Interior on San Juan Mine Lease Extension DEIS (New Mexico)

    July 9, 2018

    The Department of the Interior is proposing to extend leasing and operations at New Mexico’s San Juan mine by 15 years, producing up to 53 million additional tons of coal that will release 97.5 million tons of greenhouse gas emissions when combusted. In our comments to Interior on its draft environmental impact statement (DEIS) for the mine’s lease extension, we criticize Interior’s failure to fully account for the climate effects related to the project by monetizing the damage these emissions will cause. This refusal leaves the public and decisionmakers in the dark about the climate effects of the project, and is arbitrary given that the agency relies on the project’s monetized benefits to justify its action.

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  • Court Filings

    Brief to SCOTUS on Economic Impact of Conservation Designations

    July 6, 2018

    We recently filed, in a case before the Supreme Court, a brief on the role of ancillary and unquantified benefits in cost-benefit analysis for environmental policy. The Fish and Wildlife Service, in declaring critical habitat designation areas for the dusky gopher frog, decided to not exclude some private land from the designation after qualitatively assessing the direct and indirect costs and benefits of the designation.

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