Recent Projects

The Environmental Protection Agency (EPA) is proposing to regulate four chemicals that have serious environmental and health risks. We submitted comments supporting EPA and suggesting ways the agency can strengthen its proposal and, additionally, urging EPA to reexamine its decision not to regulate a fifth chemical.

The Bureau of Land Management (BLM) released its environmental assessment of a February 2020 lease sale in the Carlsbad Field Office region of New Mexico. We submitted joint comments asking BLM to monetize the real-world climate impacts of projected emissions using the social cost of greenhouse gases.

The Federal Motor Carrier Safety Administration (FMCSA) is proposing to revise duty length regulations for drivers of commercial motor vehicles. We submitted comments focusing on how FMCSA can improve its analysis of costs and benefits to social welfare and driver health.

The Colorado Public Utilities Commission (CPUC) proposed rule revisions to a recent clean energy bill, providing more information on how social cost of greenhouse gases (SCGG) estimates will be used. We submitted comments encouraging best practices for SCGG application that will help CPUC monetize climate externalities and weigh the costs and benefits of various decisions.

Jason Schwartz and Denise Grab prepared a testimony for the New Mexico Public Regulation Commission regarding a proposal to retire the San Juan Generating Units, a coal-fired power plant in New Mexico. Their testimony details how applying Social Cost of Carbon metrics would allow the Commission to better monetize and contextualize the climate impacts of the proposal. Retiring the San Juan coal units would deliver billions of dollars in benefits to agricultural productivity, property values, and human health.

The Bureau of Land Management released its updated environmental assessment for May 2015 and February 2016 lease sales in Utah, in response to a court remand in WildEarth Guardians v. Zinke. We submitted comments asking BLM to monetize the real-world climate impacts of the lease sales using the social cost of greenhouse gases.

The Food and Drug Administration (FDA) is proposing to place new, more effective health warning labels on cigarette packages and advertisements. We submitted comments supporting the proposal and suggesting ways the agency can strengthen its assessment of the new labels’ costs and benefits.

The Environmental Protection Agency (EPA) recently proposed to significantly weaken requirements for the disposal of coal combustion residuals from coal-fired power plants. We submitted comments focusing on inadequacies in EPA’s assessment of the rule’s costs and benefits.

The Albany County Supreme Court rejected a challenge to New York’s Zero-Emissions Credit (ZEC) program, which pays nuclear power plants for the value of avoided carbon emissions. The legal challenge focused largely on the state’s decision to use the Interagency Working Group’s Social Cost of Carbon (SCC) to value emissions.

We submitted comments to the Environmental Protection Agency (EPA) regarding changes to its New Source Review (NSR) applicability regulations. Our comments focus on EPA’s failure to perform a cost-benefit analysis for the proposed rule.