Recent Projects

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. 

We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.

If constructed, the Tennessee pipeline extension and related projects would be responsible for substantial greenhouse gas emissions. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to quantify the project’s emissions and monetize climate damages using Social Cost of Carbon estimates is arbitrary.

The Department of Labor proposed a rule that would impose limitations on investors’ ability to choose investments in Environmental Social and Governance (ESG) strategies. We worked with the Environmental Defense Fund to submit comments focusing on the proposal’s flaws.