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Joint Comments on Proposed Low Carbon Fuel Standard Amendments
The Clean Air Task Force and Pacific Environment argue that proposed LCFS amendments, including strengthened carbon intensity targets and the inclusion of intrastate aviation fuel, risk driving up demand for crop-based biofuels. They warn this could lead to increased greenhouse gas emissions from land use changes and disruptions to food markets. The authors recommend volume limits on first-generation vegetable oil-based fuels, annual market impact assessments, and extending sustainability requirements to used cooking oil and waste oils.
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Document type: Statement
Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF40 (88 Fed. Reg. 89410)
CATF supports the CFTC's oversight of voluntary carbon markets but argues that current crediting protocols are insufficient to prevent market manipulation and over-crediting. The organization recommends adding 'durability' and 'vintage' as essential commodity characteristics and requiring project-level transparency rather than relying on general protocol disclosures. CATF further urges the Commission to strengthen criteria for additionality, quantification (specifically leakage avoidance and business-as-usual baselines), and the mitigation of reversal risks, particularly for nature-based projects. Finally, it emphasizes the need for independent third-party verification to avoid conflicts of interest between project developers and verifiers.
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Document type: Statement
If your Climate Action Plan doesn’t include food waste, here’s why you should add it before the March 1 deadline
The author argues that food waste is a critical but often overlooked component of climate action plans, noting that food waste in the US generates 170 million metric tons of CO2 emissions annually. The document highlights the EPA's $4.6 billion CPRG program as a key funding opportunity for governments to implement scalable waste reduction projects, citing California's Senate Bill 1383 as a model for curbing organic waste in landfills.
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Document type: Statement
EESI’s 2023 Climate, Environmental, and Energy Congressional Hearings Tracker
The EESI 2023 Climate, Environmental, and Energy Congressional Hearings Tracker catalogs hearings across numerous House and Senate committees. House activity was led by the Natural Resources (28 hearings) and Energy and Commerce (24 hearings) committees, focusing on energy security, grid reliability, and critical minerals. Senate activity was prominent in the Environment and Public Works (22 hearings) and Budget (10 hearings) committees, with a strong emphasis on the economic costs of climate change, infrastructure resilience, and the implementation of the Inflation Reduction Act and Infrastructure Investment and Jobs Act.
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Document type: Fact sheet
How States Can Use Low-Carbon Fuel Standards to Incentivize Clean Hydrogen-Derived Fuels
The policy brief examines how Low-Carbon Fuel Standards (LCFS) can complement federal hydrogen investments by directing clean hydrogen toward high-priority sectors. It analyzes existing programs in California, Oregon, and Washington, providing four lessons for other states: regulating intrastate aviation fuel to move beyond biogenic feedstocks, phasing in maritime fuel regulation, managing biogenic feedstock demand to prevent indirect land use change, and implementing rigorous emissions accounting to avoid loopholes for blue and grey hydrogen.
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Document type: Policy brief
State of the US Clean Energy Transition: Recent Progress, and What Comes Next
The U.S. clean energy sector saw record growth in 2023, particularly in solar installations and EV sales, supported by the Inflation Reduction Act and Bipartisan Infrastructure Law. However, the transition faces significant headwinds from rising interest rates, supply chain shortages for transformers, and a lagging transmission system. To meet 2035 carbon-free electricity goals, annual renewable installation rates must nearly double, and transmission capacity may need to double or triple.
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Document type: Report
The Fraud of Plastic Recycling
The report details how the plastics industry promoted recycling as a false solution to plastic waste despite knowing it was technically and economically unviable. It outlines a history of industry tactics, from promoting disposability in the 1950s to the current promotion of 'advanced recycling' as a means to avoid bans and maintain virgin plastic production.
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Document type: Report
Impact of Investment Tax Credit on Interconnection Costs
The report analyzes the impact of a 30% Investment Tax Credit (ITC) on interconnection costs for onshore wind and solar projects in the U.S. It finds that this credit could reduce overall project costs by 3% for solar and 1.7% for wind. More significantly, the analysis suggests the ITC could have bridged the cost gap for 22 GW of withdrawn projects and 15 GW of active projects across five regions, potentially bringing a total of 26-37 GW of capacity to fruition.
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Document type: Report
45V EXEMPTIONS NEED STRONG GUARDRAILS TO PROTECT CLIMATE, GROW HYDROGEN INDUSTRY
The report analyzes the U.S. Treasury's proposed regulations for the Section 45V Clean Hydrogen Production Tax Credit, specifically focusing on the 'incrementality' requirement. It argues that a proposed 'general carve-out'—exempting a percentage of existing clean energy from incrementality rules—would lead to significant 'dirty' hydrogen production and increase CO2 emissions by inducing fossil fuel power plants to run more often. The authors suggest that such a carve-out would also discourage investment in flexible electrolyzers and hydrogen storage. Instead, the report recommends targeted exemptions for curtailed power, retirement prevention, and binding emissions caps, provided they include rigorous guardrails to prevent emissions leakage and market manipulation.
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Document type: Report
Fast-Falling Battery Prices Boost Economic Benefits Expected from Heavy-Duty Vehicle Electrification
The report argues that falling battery prices, driven by economies of scale and innovation (Wright's Law), will make battery electric heavy-duty vehicles (BEHDVs) more affordable than diesel equivalents sooner than previously estimated. Using updated BNEF forecasts, the study finds that by 2030, BEHDVs will be cheaper to purchase than diesel versions for four out of five analyzed vehicle types. This economic shift enhances the total cost of ownership (TCO) advantage and suggests that the benefits of the US EPA's proposed Phase 3 emissions standards are likely to exceed initial predictions.
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Document type: Report
Mission Critical Methane
The report identifies methane emissions from the oil and gas sector as a critical near-term climate risk and opportunity. It proposes a strategic framework based on emissions visibility, policy action, market activation, and accountability to drive the industry toward 'near-zero' leakage. Key recommendations include the adoption of low-methane procurement standards by governments and utilities, the use of third-party certifications like MiQ, and the implementation of policies to plug marginal wells. The document highlights recent regulatory moves in the U.S. and EU, and international initiatives like the MMRV and CLEAN frameworks, as essential steps to tip global gas markets toward low-emissions supplies.
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Document type: Report
A Playbook for Municipal Solid Waste Methane Mitigation
The report identifies four global municipal solid waste (MSW) management archetypes—Build the Basics (BtB), Build the Basics Plus (BtB+), Move up the Hierarchy (MuH), and Close the Circle (CtC)—and proposes specific abatement strategies for each. It emphasizes that diverting organic waste from landfills and dumpsites is the most significant opportunity for methane reduction. The authors recommend a combination of source-separated organics (SSO) programs, improved landfill gas collection and control systems (GCCS), and enabling policy frameworks, such as landfill taxes and organic waste bans, to align waste management with the waste hierarchy and limit global warming.
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Document type: Report
California Landscape of Climate Finance
CPI estimates that California requires an annual average of USD 62 billion from 2023 to 2035 to meet its climate goals, with zero-emission vehicles accounting for half of this need. While climate finance spending grew by 26% annually between 2019 and 2022, reaching USD 39 billion in 2022, a gap remains. The report notes that finance is distributed relatively evenly per capita by county and is not currently prioritized for areas with higher pollution metrics.
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Document type: Report
Time to rethink how the Impact Assessment Act weighs climate concerns
The Canadian Climate Institute suggests that using case-by-case impact assessments to determine if projects comply with emissions reduction pathways is inefficient and subjective. Instead, the author argues that overarching policies—such as industrial carbon pricing and the oil and gas emissions cap—are better suited to ensure projects align with climate goals. This shift would allow the regulatory review system to focus on averting specific environmental harms and engaging Indigenous Peoples while accelerating the approval of clean growth projects to maintain global competitiveness.
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Document type: Statement
Heavy-duty vehicles emit air pollution. EPA can change that.
The Clean Air Task Force (CATF) urges the EPA to finalize Phase 3 regulations for heavy-duty vehicles (HDVs) covering model years 2027-2032. The document highlights that HDVs contribute 59% of ozone- and particle-forming NOx emissions and 55% of particle pollution in the US, leading to significant health damages and deaths. It asserts that the industry is already transitioning toward zero-emission vehicles (ZEVs), citing new battery-electric and fuel cell electric vehicle (FCEV) models from manufacturers like Mercedes, Nikola, and Tesla. Furthermore, the document details extensive federal funding from the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) intended to build out charging and hydrogen refueling infrastructure, arguing that these resources make strong regulatory standards feasible and necessary.
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Document type: Statement
Billion-Dollar Disaster Seasons
The U.S. experienced a record 28 billion-dollar disasters in 2023, causing over $93 billion in damages. Since 1980, tropical cyclones have been the costliest events, while severe storms are the most frequent. The document details how warming temperatures intensify specific hazards—such as increasing rainfall intensity and fueling stronger tropical cyclones—and notes that the average time between such disasters has shrunk from 82 days in the 1980s to 12 days in 2023.
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Document type: Fact sheet
How to Unlock IRA CPRG Funding for the Drivers and Cyclists Most in Need
The guide outlines how to leverage the $5 billion Climate Pollution Reduction Grants (CPRG) program, specifically the $4.6 billion in competitive implementation grants. It recommends two high-impact strategies to improve EPA scoring metrics: e-bike programs and targeted EV incentives for 'superusers'—high-mileage drivers who often have lower incomes. The author argues these approaches offer clear equity advantages, straightforward emissions calculations, and address gaps in existing federal legislation.
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Document type: Guide
Produce Deliveries, Electrified
OK Produce has transitioned from diesel-powered transport to a fleet that currently includes 10 electric trucks, three electric terminal tractors, and 12 electric cars, with seven more electric trucks planned. To ensure these vehicles are fully zero emissions, the company expanded its solar capacity from an initial 231 kW system in 2001 to 3.8 MW, which now powers 90 percent of its facilities. After two decades of incremental pollution reduction via biodiesel and efficiency upgrades, the company began experimenting with electric trucks in 2020. OK Produce also participated in the late 2023 Run on Less – Electric Depot event to share data on charging infrastructure, truck performance, and total cost of ownership to accelerate industry-wide electrification.
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Document type: Case study
Community Health Impacts of Air Pollution in the U.S.
The report analyzes how the energy and transportation sectors drive air pollution in the U.S., noting that while the Clean Air Act has significantly reduced overall emissions since 1970, severe exposure disparities persist. It highlights that people of color and low-income populations are more likely to live in areas exceeding health standards, often near 'pollution hot spots' that current monitoring networks may miss. Through case studies in California, New Jersey, and Indiana, the document illustrates the specific health burdens—including asthma and cancer—borne by marginalized communities living near ports, incinerators, and coal plants.
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Document type: Report
Gas Malfunction Calling into Question the Reliability of Gas Power Plants
The document examines the vulnerability of the US gas-fired power plant fleet to extreme winter and summer weather, noting that gas plants are the primary source of generation failures during major storms. It argues that current resource adequacy metrics overvalue gas reliability and recommends transitioning to probabilistic modeling, increasing transparency, and prioritizing renewables, storage, and demand-side solutions to ensure a resilient power grid.
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Document type: Policy brief