Recent Projects

The Department of Energy (DOE) requested input on the analytical framework, models, and tools that it is using to evaluate potential standards for room air conditioners. In the technical support document, DOE departs from recent practice by proposing to focus on the domestic-only “interim” social cost of greenhouse gases estimates. We submitted joint comments recommending that DOE should, as it has in the past, continue to monetize the full climate benefits of greenhouse gas emissions reductions, using the best available estimates, which were derived by the Interagency Working Group on the Social Cost of Greenhouse Gases.

The PennEast 2020 Amendment Project, which provides for various additions to the proposed PennEast pipeline, would result in significant greenhouse gas emissions. We submitted comments on the Federal Energy Regulatory Commissions’s draft environmental assessment of the project, which fails to meaningfully assess the impact of emissions using social cost of carbon metrics.  

The Department of Energy (DOE) recently requested input on its Energy Storage Grand Challenge, which is a program aimed at expanding the development and proliferation of energy storage systems in the U.S. electric power system. We submitted comments explaining what tools and policies are necessary to ensure that energy storage systems are accurately valued and can participate fully in the market.

The Environmental Protection Agency (EPA) proposed revisions to dust-lead post-abatement clearance levels. We submitted comments emphasizing how EPA, itself, concedes that the economic analysis supporting the rule is inaccurate.

The Brattle Group developed a resource adequacy scenario analysis for the New York Public Service Commission (PSC), which is considering how to best meet its electricity generating capacity and resource adequacy needs. We submitted comments encouraging the PSC to consider several questions that Brattle’s analysis does not examine in depth.

The Environmental Protection Agency (EPA) finalized a rule delaying compliance deadlines for methane emissions controls at solid waste landfills. We filed a brief in the U.S. Court of Appeals for the D.C. Circuit focusing on EPA's failure to adequately assess the forgone benefits of the delay.

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.