Recent Projects

We submitted comments to the Federal Energy Regulatory Commission (FERC) encouraging the agency to accept PJM’s proposed changes to the Minimum Offer Price Rule, which recognizes that generation-based externality payment for clean electricity resources can be welfare-enhancing, and removes the artificial barrier to market entry for resources that receive payments under state climate policies created by the previous rule.

The East Lateral XPress Project could result in the emission of over 3.6 million tons of downstream emissions in carbon-dioxide equivalence per year from the combustion of natural gas. We submitted comments (April 2021) and a follow-up letter (August 2021) encouraging the Federal Energy Regulatory Commission to provide a more complete analysis of project emissions, weigh its climate impacts using the social cost of carbon, and consider mitigation measures.

In June 2021, the Department of the Interior’s Office of Natural Resource Revenue's (ONRR) proposed a rule rescinding a Trump-era repeal of the Valuation Rule. This rule sought to ensure that states and the federal government receive the full value of royalties due under the law for oil, gas, and coal extracted from public land. We submitted comments supporting ONRR’s proposal to fully rescind the 2020 Rule and encourage ONRR to further elaborate upon its reasons for fully withdrawing the 2020 Rule, in contrast to other alternatives. We lay out several key provisions in the 2020 Rule where ONRR can expand upon its justification for rescinding.

This comment letter follows a long line of advocacy that we've made opposing the Trump-era rule and supporting the valuation processes that it rescinded.

The Federal Energy Regulatory Commission has granted the Marcus Hook Compression Project Limited Notice to Proceed with the first phase of construction activities, which is currently underway. Our recent comments on FERC's draft environmental impact statement for the project recommend that the agency improve its consideration of climate impacts. It can do so by quantifying upstream emissions, assessing the project’s incremental climate harms, and considering avenues to mitigate its greenhouse gas contributions.

Iroquois Gas Transmission System’s Enhancement by Compression Project would provide a significant increase in natural gas compression and transportation, potentially resulting in over 2.4 million metric tons in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. We submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

The Department of Energy (DOE) has issued a notice of intent to prepare an environmental impact statement for energy conservation standards for manufactured housing. We submitted comments urging DOE to use the social cost of greenhouse gas metric whenever it analyzes the effects of greenhouse gas emissions, whether in a regulatory impact analysis, environmental impact statement, or other decisionmaking process.

We filed a brief in the U.S. District Court for the Southern District of New York supporting a challenge to the Department of Education’s replacement for a 2016 regulation known as the Borrower Defense Rule. The replacement rule makes it much harder for student borrowers who have been defrauded by for-profit colleges to get their loans discharged. We later filed a brief in the Second Circuit Court of Appeals after SDNY upheld the rule.