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Recent Projects

Viewing recent projects in Public Comments
  • Public Comments

    Comments to EPA on Water and Air Pollution Limitations from Electric Power Generation

    January 21, 2020

    The Environmental Protection Agency (EPA) proposed to weaken technology standards adopted in 2015 that act as crucial controls on effluent and emissions from electric power generation. Our comments focus on EPA’s flawed legal and economic justifications for the proposed rule, which contravenes the Clean Water Act, creates harmful incentives to delay compliance with guidelines, and relies on flawed cost-benefit analysis. We also submitted joint comments that detail how EPA severely undervalues the proposed rule’s climate costs and must monetize the full social cost of carbon using the best available data and methodologies.

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  • Public Comments

    Comments to EPA’s Chartered Science Advisory Board

    January 10, 2020

    We submitted four comments in advance of the Environmental Protection Agency’s (EPA) January 2020 meeting of its Chartered Science Advisory Board (SAB).

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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 on HHS Changes to Grant Recipient Regulations

    December 19, 2019

    The Department of Health and Human Services (HHS) is proposing to change regulations governing grant recipients, such as foster-care and adoption programs. The rule would allow discrimination on the basis of non-merit factors including sexual orientation or gender identity, likely leading to more denials of service to qualified LGBT individuals and same-sex couples. We submitted comments detailing how HHS fails to provide any analysis of the proposed rule’s costs.

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  • Public Comments

    Comments to FERC on Offshore Wind Transmission

    December 19, 2019

    Due to a significant buildout of offshore wind in the mid-Atlantic as a result of falling costs and state policy commitments, new offshore transmission will be required. However, the market rules for the nation’s largest electricity grid operator, PJM, currently provide no practical path for the development of open-access transmission to connect planned but not-yet-developed offshore wind generation. We submitted comments urging the Federal Energy Regulatory Commission to eliminate barriers to these projects, lowering transmission costs and ensuring just and reasonable rates.

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  • Public Comments

    Comments to the Department of Labor on Tip Pooling

    December 9, 2019

    The Wage and Hour Division of the Department of Labor (DOL) is proposing to implement new tip regulations under the Fair Labor Standards Act. We submitted comments asking DOL to provide a more detailed explanation of the proposed rule and improve its underlying analysis.

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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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  • 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 EPA on Water Quality Trading Proposals

    November 18, 2019

    The Environmental Protection Agency (EPA) requested input on policy approaches to promote market-based programs that will improve water quality. We submitted comments suggesting that EPA provides additional clarity, works to avoid undermining key permitting goals, and considers using alternate market-based structures before reissuing its proposals.

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