Recent Projects

The Trump administration has undertaken numerous deregulatory actions through rule suspensions; repeals; rescissions; efforts to weaken regulations through guidance, memoranda, amendments, or replacements; and more. Many of these actions have been challenged in court and decisions have been reached in several cases.

The Institute for Policy Integrity maintains a publicly available list of the outcomes of those lawsuits. This “Roundup,” which we update regularly, has been cited by the New York Times, the Wall Street Journal, the Washington Post, Bloomberg, E&E News, and the Brookings Institution.

The Roundup provides an overview of each court decision, with relevant links to the government actions and court rulings. It also tallies the successful and unsuccessful outcomes for the administration for ease of reference. Updates should be submitted to [email protected].

The Federal Energy Regulatory Commission (FERC) prepared a Draft Environmental Impact Statement (DEIS) for the Rio Grande LNG Project. Despite quantifying over 8 million metric tons of carbon dioxide-equivalent emissions per year from operations, FERC does not account for the climate effects of these emissions. We submitted joint comments that offer a detailed rejection of FERC’s arbitrary and misleading rationale for failing to monetize the project’s climate effects. We urge the agency to apply social cost of greenhouse gases estimates.

The Bureau of Land Management (BLM) recently released an Environmental Impact Statement (EIS) for the Grand Staircase-Escalante Monument and Kanab-Escalante Planning Area. We submitted comments explaining why the agency should analyze the impacts of each land management alternative using Social Cost of Greenhouse Gases estimates.

EPA recently proposed rolling back regulatory provisions that curb emissions of refrigerant substitutes, which are highly potent greenhouse gases. The agency admits that the rescissions would significantly increase the release of refrigerator hydrofluorocarbons (HFCs) but fails to monetize the climate damages caused by forgone emissions reductions. We submitted comments explaining how EPA should value the climate damages of these greenhouse gases.

The Bureau of Land Management and U.S. Forest Service recently released a Draft Environmental Impact Statement (EIS) on their land management proposal for the Bears Ears National Monument. The EIS does not consider the environmental impacts of shrinking the monument’s boundaries. We submitted comments explaining why the agencies are responsible for providing detailed environmental analysis of their proposal to alter the Bears Ears planning area.

A recently proposed rule would allow the Department of Homeland Security to indefinitely detain immigrant children who enter the U.S. in the company of a parent or guardian. Under current law, such children must be released or transferred to a non-secure, state-licensed facility within 20 days. We filed comments critiquing the Department’s assessment of the costs and benefits of this policy change.

After suggesting that state policies subsidizing clean energy are distorting capacity markets, the Federal Energy Regulatory Commission (FERC) is exploring reforms to the capacity market in PJM – the grid operator serving 13 states and Washington D.C. FERC’s reforms have the potential to undermine state policies that address climate change, such as Renewable Energy Credits and Zero Emissions Credits (we discuss this issue in depth in a recent report). We submitted comments to FERC and reply comments on the proposals.

We submitted two sets of comments to the Bureau of Land Management (BLM) in response to their Draft Resource Management Plan (RMP), which focuses on mineral development potential in the Carlsbad region of New Mexico. Our comments recommend that BLM not offer more lands for fossil fuel leasing, but instead consider alternatives with the greatest amount of conservation and wildlife protection. In particular, we focus on shortcomings in the RMP’s analysis and its failure to monetize climate damages.

EPA recently issued a proposal to replace the Clean Power Plan (CPP) with a far weaker rule that will increase greenhouse gas and soot- and smog-forming emissions from the electric sector. Our comments explain why repealing the CPP is unnecessary, irrational, and harmful.