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Comments to FERC on Middlesex Extension Natural Gas Project
We submitted comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Middlesex Extension Project in New Jersey. FERC failed to provide a meaningful analysis of the pipeline facilities' climate effects.
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Comments to FERC on NERA Net Metering Petition
The New England Ratepayers Association (NERA) recently petitioned the Federal Energy Regulatory Commission (FERC) to effectively overturn net metering policies nationwide. While FERC has previously and definitively answered the jurisdictional question concerning net metering, NERA asserts without evidence that controversy persists. We submitted comments describing the flaws of NERA’s argument and urging FERC to reject the petition.
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Comments to HHS on Blood Donation Policies
The Department of Health and Human Services (HHS) asked for public input on a forthcoming report to Congress regarding strategies for ensuring an adequate blood supply during public health emergencies. Our comments recommended that the report endorse elimination of the Food and Drug Administration’s deferral policy for donations from men who have sex with men. The policy, which bars gay and bisexual men from donating blood for three months from the date of their last sexual contact, relies on outdated science regarding HIV transmission risk, stigmatizes gay and bisexual men, and increases the likelihood of blood shortages.
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Amicus Brief in Rio Grande LNG Case
If constructed, the Rio Grande liquefied natural gas terminal and pipeline would be responsible for greenhouse gas emissions resulting in billions of dollars in climate damages. The Federal Energy Regulatory Commission’s (FERC) analysis estimates the quantity of the project’s emissions but does not analyze the context, intensity, or significance of the incremental climate damages they will cause. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to monetize the project’s climate damages using Social Cost of Carbon estimates is arbitrary.
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Comments to Oregon PUC on the Social Cost of Carbon
Oregon Governor Kate Brown signed an executive order directing state agencies, including the Public Utilities Commission (PUC), to reduce greenhouse gas emissions. We submitted comments encouraging the PUC to use Social Cost of Carbon metrics to monetize the benefits of avoided greenhouse gas emissions.
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Comments to BLM on Royal Gorge Oil and Gas Lease Sale
The Bureau of Land Management (BLM) released its environmental assessment of a September 2020 lease sale in the Royal Gorge Field Office region of Colorado. We submitted 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 to DOE on Energy Conservation Standards for Air Conditioning and Heating Equipment
The Department of Energy requested input on impact and emissions analysis for upcoming energy conservation standards. We submitted comments encouraging DOE to continue to monetize the full climate benefits of greenhouse gas emissions reductions.
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Comments to DOE on Energy Conservation Standards for Water Source Heat Pumps
The Department of Energy requested input on impact and emissions analysis for upcoming energy conservation standards. We submitted comments encouraging DOE to continue to monetize the full climate benefits of greenhouse gas emissions reductions.
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Comments to EPA Science Advisory Board on Economic Analysis Guidelines
The Environmental Protection Agency’s chartered Science Advisory Board (SAB) invited the public to comment on its new draft Guidelines for Preparing Economic Analyses. We submitted multiple sets of comments covering different portions of the guidelines.
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Comments to Colorado PUC on Valuing Distributed Energy Resources
The Colorado Public Utilities Commission (PUC) is exploring options for valuing distributed energy resources (DERs) in various contexts, including infrastructure planning, performance-based ratemaking, and others. We submitted comments identifying metrics that capture the value of DERs and suggesting how the PUC can employ those metrics to maximize benefits to the grid and society.