Recent Projects

The Colorado Public Utilities Commission is amending its rules relating to utilities, electric resource planning, and renewable energy standards. We submitted comments explaining why the Commission should use Social Cost of Greenhouse Gases estimates to monetize the externalities of carbon pollution. Our recommendations include rule revisions and new language that will help include monetized estimates of climate impacts in all relevant decisionmaking. We also submitted comments and reply comments on additional rule revisions, building on our original comments to further describe how the Commission can best express and apply the Social Cost of Greenhouse Gases.

Last year, the Environmental Protection Agency (EPA) replaced the Obama Administration’s Clean Power Plan, which sought substantial cuts in greenhouse gas emissions from power plants, with the so-called Affordable Clean Energy (ACE) rule, a far weaker policy that will, at best, yield modest reductions below business-as-usual emissions and, at worst, increase pollution from the electric sector. We filed an amicus brief in the U.S. Court of Appeals for the D.C. Circuit highlighting three key errors in EPA’s rationale for repealing the Clean Power Plan. Specifically, we explain, EPA misstates regulatory precedent and Clean Air Act legislative history supporting the Clean Power Plan and disregards the substantial harms that the ACE Rule will cause.

Advanced Energy Economy, the Electric Power Suppliers Association, and a diverse group of other stakeholders recently filed a petition for the Federal Energy Regulatory Commission (FERC) to hold a technical conference on carbon pricing in organized wholesale electricity markets. We have worked extensively to study and promote carbon pricing, publishing a comprehensive report and several academic articles. We also hosted a conference that brought together experts and stakeholders to discuss related legal, economic, and policy questions. Our comments to FERC highlight our previous work on wholesale market carbon pricing and express our support for the requested technical conference.

The Federal Energy Regulatory Commission’s (FERC) environmental assessment estimates that the Lamar County Expansion Project would result in 3.87 million metric tons of greenhouse gases from downstream emissions. We submitted comments suggesting that FERC monetize climate impacts using social cost of carbon estimates. The proposed natural gas project would result in over $200 million in annual climate costs.  

Coal combustion residuals, commonly known as coal ash, are the residual substances that remain after burning coal. They contain several chemicals that are toxic to human health, including arsenic, boron, lead, and mercury. The Environmental Protection Agency (EPA) proposed a rule that amends the regulatory framework for the disposal of coal ash. We submitted comments in January detailing how EPA fails to analyze the forgone benefits of the regulatory changes, which extend deadlines and eligibility for facilities that lack appropriate disposal capacity. We also submitted comments in April focusing on the second part of EPA's proposal, which fails to assess the forgone benefits of allowing facilities to seek approval for alternative basin liners. 

The federal Clean Car Standards promised steadily increasing fuel efficiency and lower vehicle emissions. The National Highway Traffic Safety Administration and the Environmental Protection Agency have now rolled back those standards, eviscerating important public health benefits and fuel savings for consumers. But the agencies’ own analysis shows that the rollback will cause more harm than good for society. And even the slight benefits that the agencies find under certain assumptions are premised on a flawed economic analysis that is riddled with problems.

We released a resource that explains the main economic problems with the rollback’s justification, identifying several critical errors and detailing how they invalidate the agencies' own claims

The Environmental Protection Agency’s (EPA) Federal Implementation Plan (FIP) for managing emissions on the Uintah and Ouray Indian Reservation in Utah proposes control requirements for new, modified, and existing oil and natural gas sources. Despite forecasting that the requirements would lead to a substantial decrease in methane emissions, EPA severely underestimates resulting benefits through the use of an “interim” social cost of methane metric that disregards the best peer-reviewed science. We submitted joint comments detailing EPA’s failure to adequately monetize and evaluate the benefits of the FIP.

The Environmental Protection Agency (EPA) proposed revisions to the National Primary Drinking Water Regulation for lead and copper. Our comments ask EPA to more fully monetize the benefits and better assess the significance of non-monetized benefits of the proposal. We also submitted a letter to EPA’s Science Advisory Board (SAB) summarizing our comments and encouraging the SAB to consider our points during its review of the proposed revisions.

The Federal Motor Carrier Safety Administration (FMCSA) proposed to extend the compliance dates of its entry-level commercial driver training program from 2020 to 2022. The program includes space and speed management training that reduces vehicle emissions. FMCSA projects that extending compliance dates would forgo hundreds of thousands of metric tons of greenhouse gas emissions. We submitted joint comments criticizing the agency’s regulatory impact analysis, which vastly underestimates forgone benefits and relies on flawed ‘interim values’ of the social cost of carbon.