Recent Projects

The Arizona Corporation Commission regularly requires that load serving entities (LSEs), which supply electricity to ratepayers, file plans with a 15-year time horizon disclosing environmental impacts from different resource mixes and how they will address those impacts. We submitted comments encouraging the Commission to ask that LSEs provide monetized estimates of the damages they expect to result from greenhouse gas emissions using the social cost of carbon.

The Fish and Wildlife Service (FWS) proposed amendments to its regulations for designating critical habitat. Several of FWS’s changes are inconsistent with the best practices for weighing the costs and benefits of agency action. We submitted comments explaining how the proposal is flawed in multiple ways and should not be finalized.

A rule proposed by the Department of Labor would limit the shareholder rights of Employee Retirement Income Security Act (ERISA) participants. The rule, in particular, would eliminate opportunities for ERISA fiduciaries to vote on Environmental, Social, and Governance (ESG) proposals that have long-term financial benefits for retirements plans. We worked with the Environmental Defense Fund to submit comments detailing the flaws of the Department’s rule.  

A rule by the Department of Health and Human Services would narrow the scope of civil rights protections for patients under the Affordable Care Act. We filed an amicus brief in the U.S. District Court for the Southern District of New York explaining how HHS fails to acknowledge, let alone weigh, the significant social harms resulting from the rule.

The Department of Energy (DOE) requested input on the analytical framework, models, and tools that it is using to evaluate potential standards for room air conditioners. In the technical support document, DOE departs from recent practice by proposing to focus on the domestic-only “interim” social cost of greenhouse gases estimates. We submitted joint comments recommending that DOE should, as it has in the past, continue to monetize the full climate benefits of greenhouse gas emissions reductions, using the best available estimates, which were derived by the Interagency Working Group on the Social Cost of Greenhouse Gases.

The PennEast 2020 Amendment Project, which provides for various additions to the proposed PennEast pipeline, would result in significant greenhouse gas emissions. We submitted comments on the Federal Energy Regulatory Commissions’s draft environmental assessment of the project, which fails to meaningfully assess the impact of emissions using social cost of carbon metrics.  

The Department of Energy (DOE) recently requested input on its Energy Storage Grand Challenge, which is a program aimed at expanding the development and proliferation of energy storage systems in the U.S. electric power system. We submitted comments explaining what tools and policies are necessary to ensure that energy storage systems are accurately valued and can participate fully in the market.