Recent Projects

Connecticut’s Department of Energy and Environmental Protection (DEEP) and Public Utilities Regulatory Authority (PURA) are conducting a study to determine how it can best compensate distributed energy resources, like solar panels and residential battery installations, which can provide provide significant value to the grid. DEEP and PURA’s study involves an electric system dispatch simulation model and various DER technology use cases. We submitted comments on the model’s outputs and how they can be improved to better serve the study.

The Department of Energy requested input on its analysis of energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers. We submitted comments encouraging DOE to, as it has in the past, monetize the full climate benefits of greenhouse gas emission reductions.

The Pecos District Office of the Bureau of Land Management (BLM) released an environmental assessment of a 2020 oil and gas lease sale in New Mexico. Despite calculating that foreseeable leasing activities would produce over 28 millions tons of downstream CO2-equivalent over a 20-year time horizon, BLM fails to monetize the real-world impacts of those emissions. We submitted comments encouraging BLM to estimate climate impacts using social cost of carbon metrics.

The Bureau of Land Management’s (BLM) activity plan for the Alaska National Petroleum Reserve could lead to as much as 76.86 million tons of greenhouse gas emissions in a given year during peak production. We submitted joint comments urging BLM to monetize and contextualize the climate impacts of its plan using social cost of carbon metrics.

The Securities and Exchange Commission (SEC) proposed a rule that would limit investors’ ability to propose shareholder resolutions for a vote by fellow shareholders. The rule would raise requirements on the amount of stock required to be owned, impose requirements for the length of time the stock must have been held, and make it harder to resubmit resolutions that had failed to reach majority support in prior years. We submitted comments critiquing the rule, which will limit shareholder monitoring and likely have an outsized impact on shareholders’ role in environmental oversight.

The Centers for Medicare and Medicaid Services at the Department of Health and Human Services proposed a rule that would likely reduce Medicaid funding, provider payments, and beneficiaries’ access to care. We submitted comments explaining serious flaws in the agency’s analysis, which fails to quantify funding reductions and assess the health impacts of reduced care.

Several states have determined that ensuring the viability of zero-emission electricity generation from nuclear power is critical to mitigating the impacts of climate change especially in the short term while states work to meet aggressive new clean energy goals. Through comments and amicus briefs, we’ve been involved in those efforts in both New York and New Jersey.

The Environmental Protection Agency (EPA) finalized a rule revising standards for lead found in dust on floors, window sills, and in soil. Our amicus brief critiques the rule, which forgoes net beneficial options in favor of weaker standards that will cause significant harms to public health.

The Environmental Protection Agency (EPA) proposed to weaken technology standards adopted in 2015 that act as crucial controls on effluent and emissions from electric power generation. Our comments focus on EPA’s flawed legal and economic justifications for the proposed rule, which contravenes the Clean Water Act, creates harmful incentives to delay compliance with guidelines, and relies on flawed cost-benefit analysis. We also submitted joint comments that detail how EPA severely undervalues the proposed rule’s climate costs and must monetize the full social cost of carbon using the best available data and methodologies.