Recent Projects

The Environmental Protection Agency (EPA) proposed revisions to dust-lead post-abatement clearance levels. We submitted comments emphasizing how EPA, itself, concedes that the economic analysis supporting the rule is inaccurate.

The Brattle Group developed a resource adequacy scenario analysis for the New York Public Service Commission (PSC), which is considering how to best meet its electricity generating capacity and resource adequacy needs. We submitted comments encouraging the PSC to consider several questions that Brattle’s analysis does not examine in depth.

The Environmental Protection Agency (EPA) finalized a rule delaying compliance deadlines for methane emissions controls at solid waste landfills. We filed a brief in the U.S. Court of Appeals for the D.C. Circuit focusing on EPA's failure to adequately assess the forgone benefits of the delay.

As the climate crisis intensifies, it is crucial that we effectively contextualize and consider how policies affect our climate. We have worked hard to ensure that governments, regulators, and courts account for the social cost of carbon in policy and decisionmaking—and a string of recent policy outcomes has created positive momentum.

The Bureau of Land Management (BLM) announced its decision to exclude 87,000 acres of public lands from an upcoming lease sale, agreeing with arguments raised by policymakers and environmental advocates, including Policy Integrity, that these public lands are too valuable for other uses to be designated for fossil fuel extraction.

The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. We submitted comments encouraging BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. We also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal. 

The Environmental Protection Agency (EPA) proposed a rule adjusting the test procedures to calculate greenhouse gas emissions and fuel economy rates for the GHG and CAFE programs and the Fuel Economy and Environment Label upon adoption of Tier 3 certification test fuel. We submitted comments that encourage EPA to finalize the proposal, and explain that EPA would be required to provide a new proposal, rationale, and analysis if it chooses to forgo the GHG emissions test adustment.