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Recent Projects

Viewing recent projects in Natural Resources
  • Public Comments

    Comments to EPA on Methane Emissions from Oil and Gas Operations

    November 25, 2019

    The Environmental Protection Agency (EPA) proposed revisions to New Source Performance Standards from methane and volatile organic compound (VOC) emissions in the oil and gas sector. We submitted comments focusing on EPA’s flawed and legal economic justifications for the rule.

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  • New Resource on Climate Damages of U.S. LNG Exports

    November 21, 2019

    The Institute for Policy Integrity has launched a new resource that compiles the greenhouse gas emissions and resulting damages from liquefied natural gas (LNG) export terminals.

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  • Public Comments

    Comments to the State Department on the Proposed Keystone XL Pipeline

    November 18, 2019

    We submitted comments on the U.S. Department of State’s supplemental environmental impact statement for the proposed Keystone XL Pipeline project. A federal district court ruled that the agency’s original impact analysis was inadequate, failing to take all relevant information into account when projecting that the pipeline would not affect total crude oil production. The Department’s new analysis projects that the pipeline will likely increase total crude oil production by only partially offsetting production that would have occurred elsewhere under a “no action” scenario, but irrationally fails to account for this substitution effect when projecting the pipeline’s economic benefits. Our comments argue that the Department continues to violate NEPA by its lopsided treatment of the pipeline’s costs and benefits, through not only its inconsistent treatment of substitution effects but also its failure to assess the pipeline’s climate-related impacts through monetization.

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  • Public Comments

    Comments to BLM on New Mexico Oil and Gas Lease Sale

    October 28, 2019

    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.

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  • Public Comments

    Comments to BLM on Utah Oil and Gas Lease Sale

    October 18, 2019

    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.

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  • Public Comments

    Comments to BLM on Moneta Divide Oil and Gas Project

    July 18, 2019

    The Bureau of Land Management (BLM) released its environmental impact statement for the Moneta Divide Natural Gas and Oil Development Project, which would significantly expand well drilling in Wyoming. The project would be responsible for billions of tons of greenhouse gas emissions over its lifetime. We submitted comments explaining why BLM should use the social cost of greenhouse gases to monetize and weigh the plan’s climate impacts.

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  • Public Comments

    Comments to FERC on Jordan Cove Natural Gas Project

    July 5, 2019

    We submitted joint comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Jordan Cove natural gas exports project in Oregon. FERC failed to provide a meaningful analysis of the pipeline’s climate effects.

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  • Court Filings

    Amicus Brief on Repeal of Fracking Rule

    July 1, 2019

    In 2017, the Bureau of Land Management (BLM) repealed an Obama-era rule that tightens environmental regulations for fracking on public lands. We filed an amicus brief detailing BLM’s irrational analysis of the repeal, which erases the rule’s significant net benefits and flouts longstanding standard practices.

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  • Public Comments

    Comments to the Army Corps of Engineers on the Pebble Mine Project

    July 1, 2019

    We submitted joint comments on the Army Corps of Engineers’ environmental assessment of the Pebble Mine Project in southwest Alaska. The Corps quantifies greenhouse gas emissions from the project but fails to provide a monetized estimate of the climate damages those emissions will produce.

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  • Court Filings

    Amicus Brief on BLM’s Repeal of Waste Prevention Rule

    June 21, 2019

    Last year, the Bureau of Land Management (BLM) repealed its Waste Prevention Rule, undoing crucial regulations that reduce natural gas waste from venting, flaring, and leaks. We submitted an amicus brief focusing on the problematic aspects of the repeal: BLM’s false understanding of its role in waste prevention and its faulty analysis of climate impacts.

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