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Comments to the New York Public Service Commission on Resource Adequacy
We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.
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Comments to DOE on Conservation Standards for General Service Lamps
The Department of Energy (DOE) made an initial determination that energy conservation standards for general service incandescent lamps do not need to be amended, even though improved efficiency is technologically feasible and a new standard would save consumers billions of dollars. We submitted comments detailing the flaws of DOE’s economic justification for its proposed decision.
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Comments to Massachusetts on Clean Peak Energy Standards
The Massachusetts Department of Energy Resources is adopting a program that incentivizes the adoption of energy storage resources with the aim of displacing high-pollution resources during peak periods of energy use. We submitted comments that explain potential risks of energy storage integration and encourage Massachusetts to adjust its clean peak policies to maximize the emissions reduction potential of the state’s energy storage resources.
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Comments to BLM on Willow Master Development Plan
The Bureau of Land Management (BLM) released its environmental impact analysis of the Willow Master Development Plan, estimating the project will produce more than 260 million metric tons of greenhouse gas emissions. We submitted joint comments asking BLM to monetize the real-world climate effects of those emissions using the social cost of greenhouse gases.
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Comments to EPA on TSCA Chemicals Regulation
The Environmental Protection Agency (EPA) is proposing to regulate four chemicals that have serious environmental and health risks. We submitted comments supporting EPA and suggesting ways the agency can strengthen its proposal and, additionally, urging EPA to reexamine its decision not to regulate a fifth chemical.
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Comments to BLM on New Mexico Oil and Gas Lease Sale
The Bureau of Land Management (BLM) released its environmental assessment of a February 2020 lease sale in the Carlsbad Field Office region of New Mexico. We submitted joint comments asking BLM to monetize the real-world climate impacts of projected emissions using the social cost of greenhouse gases.
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Comments on Duty Length Regulations for Commercial Vehicle Drivers
The Federal Motor Carrier Safety Administration (FMCSA) is proposing to revise duty length regulations for drivers of commercial motor vehicles. We submitted comments focusing on how FMCSA can improve its analysis of costs and benefits to social welfare and driver health.
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Comments on Colorado’s Use of the Social Cost of Greenhouse Gases
The Colorado Public Utilities Commission (CPUC) proposed rule revisions to a recent clean energy bill, providing more information on how social cost of greenhouse gases (SCGG) estimates will be used. We submitted comments encouraging best practices for SCGG application that will help CPUC monetize climate externalities and weigh the costs and benefits of various decisions.
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Testimony on Retirement of the San Juan Coal-Fired Power Plant
Jason Schwartz and Denise Grab prepared a testimony for the New Mexico Public Regulation Commission regarding a proposal to retire the San Juan Generating Units, a coal-fired power plant in New Mexico. Their testimony details how applying Social Cost of Carbon metrics would allow the Commission to better monetize and contextualize the climate impacts of the proposal. Retiring the San Juan coal units would deliver billions of dollars in benefits to agricultural productivity, property values, and human health.
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Comments to BLM on Utah Oil and Gas Lease Sale
The Bureau of Land Management released its updated environmental assessment for May 2015 and February 2016 lease sales in Utah, in response to a court remand in WildEarth Guardians v. Zinke. We submitted comments asking BLM to monetize the real-world climate impacts of the lease sales using the social cost of greenhouse gases.