Recent Projects

The Putnam Expansion Project involves the construction and installation of natural gas infrastructure that will result in downstream emissions of approximately 3.26 million metric tons carbon dioxide-equivalent each year. Our comments to the Federal Energy Regulatory Commission (FERC) focus on its environmental assessment of the project, which provides unclear and inadequate analysis of the emissions and their climate impacts. We urge FERC to monetize climate damages by using social cost of greenhouse gas metrics.

The Department of Energy proposed to not increase the efficiency of fluorescent lamp ballasts. We submitted comments noting that DOE fails to analyze the forgone emissions reductions of its proposed determination.

The Department of Health and Human Services (HHS) is proposing to change regulations governing grant recipients, such as foster-care and adoption programs. The rule would allow discrimination on the basis of non-merit factors including sexual orientation or gender identity, likely leading to more denials of service to qualified LGBT individuals and same-sex couples. We submitted comments detailing how HHS fails to provide any analysis of the proposed rule’s costs.

Due to a significant buildout of offshore wind in the mid-Atlantic as a result of falling costs and state policy commitments, new offshore transmission will be required. However, the market rules for the nation’s largest electricity grid operator, PJM, currently provide no practical path for the development of open-access transmission to connect planned but not-yet-developed offshore wind generation. We submitted comments urging the Federal Energy Regulatory Commission to eliminate barriers to these projects, lowering transmission costs and ensuring just and reasonable rates.

The National Highway Traffic Safety Administration (NHTSA) recently finalized a rule that significantly reduces the penalties that automakers pay for violating the corporate average fuel economy (CAFE) standards. In reducing the penalty, NHTSA rolled back an adjustment that had been made to the penalty under the Inflation Act, a statute requiring agencies to adjust civil monetary penalties to account for decades of inflation. We submitted an amicus brief in the Court of Appeals for the Second Circuit focusing on NHTSA’s faulty economic justifications for the rule, arguing that this repeal was unlawful.

The Bureau of Land Management failed to consider the climate impacts of oil and gas leasing activity in Colorado that would produce 317 million tons of carbon dioxide-equivalent over a 30-year period in upstream and downstream emissions. We submitted comments urging the agency to apply the social cost of greenhouse gases in its environmental assessment. 

The Bureau of Land Management failed to estimate the climate impacts of leasing activity that would produce over 5 million tons of carbon dioxide-equivalent in downstream emissions on an annual basis. We submitted comments urging the agency to use the social cost of greenhouse gases in its environmental assessment. 

The Wage and Hour Division of the Department of Labor (DOL) is proposing to implement new tip regulations under the Fair Labor Standards Act. We submitted comments asking DOL to provide a more detailed explanation of the proposed rule and improve its underlying analysis.