Recent Projects

The Department of Energy proposed revisions to its procedures and policies for considering new energy conservation standards across a range of consumer products and commercial equipment. We submitted comments offering support for the proposed revisions and making additional recommendations. Our recommendations include weighing a full range of environmental and consumer effects, incorporating the consideration of distributional justice, and reviewing the selection of discount rates. 

The Rail Tie Wind Project would offset approximately 900,000 metric tons of carbon dioxide emissions annually compared to typical U.S. electric generation. We submitted comments encouraging the Western Area Power Administration to provide context for those emission offsets by using the social cost of greenhouse gases.

The Maryland Public Service Commission requested input on its working group's energy storage report. We submitted comments in support of several of the working group's recommendations. We also encourage the Commission to apply the same principles that inform the report to assess the net emissions impacts of energy storage installations.

The New York Public Service Commission requested input on its Staff Gas System Planning Process Proposal. We submitted comments encouraging the Commission to add several minor requirements and directly address the legal tensions and ambigious policies that make planning decisions more challenging.

The Federal Energy Regulatory Commission (FERC) requested input on the expanded minimum offer price rule (Expanded MOPR) in the PJM capacity market, as well as prospective alternative approaches that could replace PJM's Expanded MOPR. We submitted comments addressing the questions posed while drawing attention to reforms that FERC should undertake.

The Federal Regulatory Energy Commission (FERC) solicited comment from interested parties on how the Commission should structure their Office of Public Participation to facilitate public engagement. We submitted comments highlighting the potential benefits of public participation by environmental justice communities and identifying best practices that FERC’s Office of Public Participation (OPP) should adopt.

The Department of Interior delayed the effective date of a Trump-era rule that lowers the royalty burden on corporations extracting fossil fuels on public lands. We provided significant input on the review of the rule, helping guide ONRR’s decision to delay the rule and further examine its legality and impact.

The Federal Housing Finance Agency requested information on the risks that climate change and natural disasters pose to the housing finance system. We submitted short comments and attached our report with the Environmental Defense Fund, Mandating Disclosure of Climate-Related Financial Risk, which surveys the variety of risks that U.S. corporations, including those in the housing sector, face from climate change’s physical effects and policy and market consequences.