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Recent Projects

Viewing recent projects in Natural Resources
  • Public Comments

    Comments to BLM on Oil and Gas Lease Sale in New Mexico

    February 7, 2020

    The Pecos District Office of the Bureau of Land Management (BLM) released an environmental assessment of a 2020 oil and gas lease sale in New Mexico. Despite calculating that foreseeable leasing activities would produce over 28 millions tons of downstream CO2-equivalent over a 20-year time horizon, BLM fails to monetize the real-world impacts of those emissions. We submitted comments encouraging BLM to estimate climate impacts using social cost of carbon metrics.

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  • Public Comments

    Comments to BLM on Alaska’s National Petroleum Reserve

    February 5, 2020

    The Bureau of Land Management’s (BLM) activity plan for the Alaska National Petroleum Reserve could lead to as much as 76.86 million tons of greenhouse gas emissions in a given year during peak production. We submitted joint comments urging BLM to monetize and contextualize the climate impacts of its plan using social cost of carbon metrics.

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  • Public Comments

    Comments to EPA on Coal Combustion Residuals Rule

    January 31, 2020

    Coal combustion residuals, commonly known as coal ash, are the residual substances that remain after burning coal. They contain several chemicals that are toxic to human health, including arsenic, boron, lead, and mercury. The Environmental Protection Agency (EPA) proposed a rule that amends the regulatory framework for the disposal of coal ash. We submitted comments detailing how EPA fails to analyze the forgone benefits of the regulatory changes, which extend deadlines and eligibility for facilities that lack appropriate disposal capacity.

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  • Reports

    Look Before You Lease

    January 7, 2020

    While the Trump administration’s goal of “energy dominance” has increased the public lands available for oil and gas development, no effort has been made to modernize the leasing system, even in the face of climate change. Our report explains how option value—which accounts for the informational value gained by delaying leasing decisions—can and should be factored into the Bureau of Land Management’s land use planning processes. Accounting for option value at multiple stages of the land use planning process would significantly improve BLM’s public lands stewardship, better protect the environment, and regain some of the economic and strategic advantages it has ceded to private developers. The report also describes case studies where BLM’s failure to consider option value has led to costly litigation and missed opportunities.

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  • Public Comments

    Comments to BLM on Proposed Farmington Drilling Projects

    January 6, 2020

    The Bureau of Land Management’s (BLM) Farmington Field Office in New Mexico released an addendum to its environmental assessment for eighty-six drilling applications. The addendum estimates that the projects, in total, would result in more than 483 million metric tons of carbon dioxide-equivalent over the lifetimes of the assessments. BLM’s analysis, however, fails to consider the climate impacts of these emissions, which would amount to more than $25 billion. Our comments ask that BLM provide monetized estimates of these real-world climate impacts using social cost of greenhouse gases metrics.

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  • Public Comments

    Comments to FERC on Putnam Expansion Project

    January 6, 2020

    The Putnam Expansion Project involves the construction and installation of natural gas infrastructure that will result in downstream emissions of approximately 3.26 million metric tons carbon dioxide-equivalent each year. Our comments to the Federal Energy Regulatory Commission (FERC) focus on its environmental assessment of the project, which provides unclear and inadequate analysis of the emissions and their climate impacts. We urge FERC to monetize climate damages by using social cost of greenhouse gas metrics.

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  • 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 for methane and volatile organic compound (VOC) emissions from the oil and natural 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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