Comments, Legal Briefs, and Testimonies
The Sabin Center frequently engages with federal, state and local agencies by submitting comment letters urging decision-makers to account for the causes and effects of climate change when deciding whether and how to proceed with proposed regulations, guidance documents, and projects undergoing environmental reviews. We also submit comments to technical conferences. On some occasions, we also engage directly with courts by submitting amicus briefs in cases involving climate change law and policy. We also submit written testimonies at both the domestic and international levels.
This page contains downloadable copies of all of the Sabin Center’s comment letters, legal briefs, and testimonies. These include:
Legal Briefs
Amicus Brief submitted by the Sabin Center for Climate Change Law in Support of New York City in Glen Oaks Village Owners, et al. v. City of New York, et al., by Amy Turner, Michael Burger, and Vincent Nolette (December 2024)
The Sabin Center filed an Amicus Brief in support of New York City in Glen Oaks Village Owners, et al. v. City of New York, et al., before the New York State Court of Appeals. The court must answer whether New York City’s New York City’s building performance standards aimed at reducing greenhouse gas (GHG) emissions from the City’s largest buildings, is preempted by New York State’s Climate Leadership and Community Protection Act (CLCPA).
Answer of Clara and Leonard Ostrander, Teresa Himes, and Kevin Heath in Almer Charter Township v. Michigan Public Service Commission, by Mark Brewer, Rowan Coneybeare, and Matthew Eisenson (December 2024)
The Sabin Center, together with the law firm Goodman Acker P.C., filed this answer in response to a motion to file a substantive response to their amicus brief opposing a motion for a preliminary injunction to stop Michigan's new siting process for large-scale renewables from going into effect.
Amicus Brief of Clara and Leonard Ostrander, Teresa Himes, and Kevin Heath in Almer Charter Township v. Michigan Public Service Commission, by Mark Brewer, Rowan Coneybeare, and Matthew Eisenson (December 2024)
The Sabin Center, together with the law firm Goodman Acker P.C., filed an amicus brief opposing a motion for a preliminary injunction that, if granted, would stop the Michigan Public Service Commission's new siting process for large-scale renewables from going into effect.
Amicus Brief on behalf of the National League of Cities and the U.S. Conference of Mayors in Support of EPA in Kentucky v. EPA, by Michael Burger, Amy Turner, Olivia Guarna, and Vincent Nolette (December 2024)
The Sabin Center filed an amicus brief on behalf of the National League of Cities and the U.S. Conference of Mayors in support of the U.S. Environmental Protection Agency (EPA) in Kentucky v. EPA, the lawsuit challenging the EPA’s 2024 Light- and Medium-Duty Vehicle Emissions Standards.
Motion to Intervene in the Matter of Eastern Cottontail Solar, LLC, by Matthew Eisenson & Trent Dougherty (November 2024)
The Sabin Center, together with local counsel, filed a motion on behalf of local residents Betsy Alt and Allen Turnbull to intervene in an Ohio Power Siting Board proceeding in support of the proposed 220-MW Eastern Cottontail Solar Project.
Reply Brief of Bruce Beery and Ashley Beery in the Matter of the Application of Richwood Solar, LLC by Jacob Elkin & Trent Dougherty (October 2024)
The Sabin Center, together with local counsel, filed this post-hearing brief before the Ohio Power Siting Board in support of the Richwood Solar Project, which would include 250 MW of generation capacity and 50 MW of battery storage capacity.
Reply Brief of Ethan Robertson in the Matter of the Application of Frasier Solar, LLC by Matthew Eisenson, Jacob Elkin, and Trent Dougherty (October 2024)
The Sabin Center, together with local counsel, filed this post-hearing brief before the Ohio Power Siting Board in support of the 120-MW Frasier Solar Project.
Amicus Brief on behalf of the National League of Cities and the U.S. Conference of Mayors in Support of EPA in West Virginia v. EPA, by Michael Burger, Amy Turner, and Vincent Nolette (October 2024)
The Sabin Center filed an amicus brief on behalf of the National League of Cities and the U.S. Conference of Mayors in support of the U.S. Environmental Protection Agency (EPA) in West Virginia v. EPA, the lawsuit challenging the EPA’s 2024 Power Plant Rules. The brief highlights the climate impacts that cities already experience, and local governments' efforts to mitigate and adapt to climate change.
Amicus Brief of Carbon Capture and Storage Scientists and Engineers in Support of EPA in West Virginia v. EPA, by Michael Burger and Romany Webb, with contributions from Olivia Guarna (October 2024)
The Sabin Center filed an amicus brief on behalf of Carbon Capture and Storage scientists and engineers in support of Respondent EPA in West Virginia v. EPA, which is a challenge to EPA's recent rules on greenhouse gas emissions from fossil fuel power plants.
Initial Post-Hearing Brief of Bruce Beery and Ashley Beery in the Matter of the Application of Richwood Solar, LLC by Jacob Elkin & Trent Dougherty (September 2024)
The Sabin Center, together with local counsel, filed this post-hearing brief before the Ohio Power Siting Board in support of the Richwood Solar Project, which would include 250 MW of generation capacity and 50 MW of battery storage capacity.
Initial Post-Hearing Brief of Ethan Robertson in the Matter of the Application of Frasier Solar, LLC by Matthew Eisenson, Jacob Elkin, and Trent Dougherty (September 2024)
The Sabin Center, together with local counsel, filed this post-hearing brief before the Ohio Power Siting Board in support of the 120-MW Frasier Solar Project.
Amicus Brief submitted by the Sabin Center for Climate Change Law in Support of New York City's Motion for Leave to Appeal to the New York State Court of Appeals in Local Law 97 case, by Amy Turner, Michael Burger, and Vincent Nolette (June 2024)
The Sabin Center filed an Amicus Brief in support of New York City's Motion for Leave to Appeal to the New York State Court of Appeals in the case involving a challenge to New York City's Local Law 97.
Motion to Intervene in the Matter of Clear Mountain Energy Center, LLC, by Matthew Eisenson & Trent Dougherty (June 2024)
The Sabin Center, together with local counsel, filed a motion on behalf of local residents Gregory Bruns and Gregory Vestring to intervene in an Ohio Power Siting Board proceeding in support of the proposed Clear Mountain Energy Center, which would include 100 MW of solar generation capacity and 52 MW of battery storage capacity.
(Second) Amicus Brief of Climate Action Rhode Island in Green Oceans v. U.S. Dep't of Interior, by Josh C. Toll, Lauren Friedman, Jessica Beess und Chrostin, Carson W. Bennett, Kanzanira Thorington, Matthew Eisenson & Jacob Elkin (May 2024)
The Sabin Center, together with King & Spalding LLP, filed a second amicus brief on behalf of Climate Action Rhode Island (CARI) to oppose Green Oceans' second motion for a preliminary injunction to halt construction of the 704-MW Revolution Wind project.
Motion to Intervene in the Matter of Richwood Solar, LLC, by Jacob Elkin & Trent Dougherty (May 2024)
The Sabin Center, together with local counsel, filed a motion on behalf of local residents Ashley Beery and Bruce Beery to intervene in an Ohio Power Siting Board proceeding in support of the proposed Richwood Solar Project, which would include 250 MW of generation capacity and 50 MW of battery storage capacity.
Brief of Dr. John Boeckl Contra Rehearing in the Matter of the Application of Oak Run Solar Project, LLC, by Matthew Eisenson, Michael Gerrard, and Trent Dougherty (April 2024)
The Sabin Center, together with local counsel, filed a brief opposing a request for rehearing of the Ohio Power Siting Board's March 2024 decision to approve the 800-MW Oak Run Solar Project.
Amicus Brief of Climate Action Rhode Island in Green Oceans v. U.S. Dep't of Interior, by Josh C. Toll, Lauren Friedman, Jessica Beess und Chrostin, Carson W. Bennett, Kanzanira Thorington, Matthew Eisenson & Jacob Elkin (April 2024)
The Sabin Center, together with King & Spalding LLP, filed an amicus brief on behalf of Climate Action Rhode Island (CARI) in opposition to a motion for a preliminary injunction to halt construction of the 704-MW Revolution Wind project.
Motion to Intervene in the Matter of Frasier Solar, LLC, by Jacob Elkin & Trent Dougherty (February 2024)
The Sabin Center, together with local counsel, filed a motion on behalf of participating landowner Ethan Robertson to intervene in an Ohio Power Siting Board proceeding in support of the proposed 120-MW Frasier Solar Project.
Amicus Brief submitted by the Sabin Center for Climate Change Law in support of plaintiffs in the Willow Project Case, by Michael Burger & Jessica Wentz (January 2024)
In November, the U.S. District Court of Alaska dismissed 2 lawsuits seeking to halt the Willow oil and gas project. Now, the case will be heard by the Ninth Circuit on appeal, and the Sabin Center has filed an amicus brief in support of the Plaintiffs-Appellants. The brief identifies several specific legal deficiencies in BLM’s analysis of climate change-related considerations for the Willow Project.
The Sabin Center filed an amicus brief on behalf of the National League of Cities, the League of California Cities & California State Association of Counties In Support of the City of Berkeley's Petition for Rehearing En Banc before the Ninth Circuit in California Restaurant Ass'n v. City of Berkeley.
Comments from the Sabin Center's Peer Review Network on Global Climate Change Litigation to the 'Study on the Impact of Climate Change on Human and Peoples' Rights in Africa' submitted to the African Commission on Human and Peoples' Rights (November 2023) by Maria Antonia Tigre et al.
Amicus Brief submitted by the Sabin Center for Climate Change Law on Climate Science and Human Rights Obligations to the Inter-American Court of Human Rights on the Request for an Advisory Opinion on the Climate Emergency and Human Rights from the Republic of Colombia and the Republic of Chile (November 2023) by Jessica Wentz, Michael Burger, Maria Antonia Tigre and Michael Gerrard
Reply Brief of Dr. John Boeckl in the Matter of the Application of Oak Run Solar Project, LLC by Matthew Eisenson, Michael Gerrard, and local counsel Trent Dougherty (July 2023)
Initial Post-Hearing Brief of Dr. John Boeckl in the Matter of the Application of Oak Run Solar Project, LLC by Matthew Eisenson, Michael Gerrard, and local counsel Trent Dougherty (July 2023)
Amicus Brief of the Sabin Center for Climate Change Law in Sovereign Iñupiat for a Living Arctic v. Bureau of Land Management, by Michael Burger, Jessica Wentz, and Romany Webb (July 2023)
The Sabin Center filed an amicus brief in support of plaintiffs in litigation regarding the Willow Project on the North Slope of Alaska
Amicus Brief National League of Cities, League of California Cities & California State Association of Counties In Support of Defendant-Appellee City of Berkeley's Petition for Rehearing En Banc in California Restaurant Ass'n v. City of Berkeley, by Michael Burger and Amy Turner (June 2023)
Motion to Intervene in the Matter of the Application of Oak Run Solar Project, LLC by Matthew Eisenson, Michael Gerrard, and local counsel Trent Dougherty (March 2023)
The Sabin Center, together with local counsel, filed a motion on behalf of local resident Dr. John Boeckl to intervene in an Ohio Power Siting Board proceeding in support of the proposed 800-MW Oak Run Solar Project.
Amicus Brief of the National League of Cities and U.S. Conference of Mayors in Texas v. EPA by Michael Burger, Martin Lockman, Andrea Nishi, and Amy Turner (March 2023).
The Sabin Center filed an amicus brief on behalf of the National League of Cities and U.S. Conference of Mayors in support of EPA's revised light-duty vehicle emissions standards.
Third-party intervention in the case of Verein KlimaSeniorinnen and others v Switzerland (Application no. 53600/20) (December 5, 2023) by Michael Burger and Maria Antonia Tigre
Amicus Brief of Friends of Flint Mine Solar et al. in Town of Copake v. New York State Office of Renewable Energy Siting by Michael B. Gerrard, Matthew Eisenson, and Maureen Crough (December 2, 2022).
The Sabin Center filed an amicus brief on behalf of local farmers and community groups in support of the siting regulations promulgated by the New York State Office of Renewable Energy Siting.
Amicus Brief of Catskill Mountainkeeper and Win With Wind in Town of Blenheim v. Hiller by Michael B. Gerrard and Matthew Eisenson (June 2022)
The Sabin Center filed an amicus brief on behalf of two environmental organizations in opposition to a motion for a preliminary injunction that would delay implementation of the New York State Department of Taxation and Finance's wind and solar appraisal model.
Amicus Brief of Local Farmers in In the Matter of the Application of Firelands Wind LLC by Michael B. Gerrard and local counsel Trent A. Dougherty (June 2022)
The Sabin Center filed an amicus brief on behalf of two local farmers in Ohio in support of a 300-megawatt wind energy project that will benefit the local economy while avoiding greenhouse gas emissions
Local Government Amicus Brief in California Restaurant Association v. City of Berkley by Michael Burger, Jennifer Danis and Amy Turner (February 2022)
Local Government Amicus Brief in West Virginia v. EPA by Michael Burger (January 2022)
The Sabin Center filed an amicus brief on behalf of the National League of Cities and the U.S. Conference of Mayors in West Virginia v. EPA, a case that is currently before the United States Supreme Court. The case concerns the scope of the United States Environmental Protection Agency’s (EPA) authority to regulate greenhouse gas emissions from existing fossil fuel power plants under Section 111(d) of the Clean Air Act (CAA). The brief argues that significant federal regulation of power plants’ emissions is necessary to support and supplement local climate action, that Section 111(d) does not foreclose generation-shifting regulation, and that neither the major questions doctrine nor the federalism clear statement canon are implicated by the case.
Local Government Amicus Brief in Competitive Enterprise Institute v. NHTSA by Michael Burger and Hillary Aidun and related press release (January 2021)
The Sabin Center filed an amicus brief on behalf of local governments in support of state, city, environmental, and public health petitioners to challenge the Trump Administration's rollback of clean car standards. The brief illustrates the threats that motor vehicle emissions pose to cities, and that the federal weakening of motor vehicle standards undermines local government efforts to address climate change and transportation pollution. The brief was joined by the National League of Cities, U.S. Conference of Mayors, and 15 individual cities, towns, counties, and mayors.
Local Government Amicus Brief in Union of Concerned Scientists v. NHTSA by Michael Burger and Hillary Aidun (July 2020)
The Sabin Center filed an amicus brief on behalf of local government associations in support of state, city, environmental, and industry petitioners in the lawsuit challenging the Trump Administration's withdrawal of California’s authority to implement its existing greenhouse gas and zero-emission vehicle standards. The brief illustrates the threats that motor vehicle emissions pose to cities, including climate impacts and public health harms associated with smog and particulate matter. The brief also emphasizes that the EPA failed to consider the need to address climate change and vehicle pollution, and unlawfully disregarded the environmental justice impacts of its action. The brief was filed on behalf of the National League of Cities, the U.S. Conference of Mayors, and the International Municipal Lawyers Association.
Local Government Amicus Brief in American Lung Association v. EPA by Michael Burger and Hillary Aidun and related press release (April 2020)
The Sabin Center filed an amicus brief on behalf of local governments in support of state and environmental petitioners in American Lung Association v. EPA, the lawsuit challenging the Environmental Protection Agency's repeal of the Clean Power Plan and its replacement, the Affordable Clean Energy Rule. The brief highlights the climate impacts that cities are already facing, and local governments' efforts to mitigate and adapt to climate change. The coalition members include the U.S. Conference of Mayors, the National League of Cities, and 23 cities, towns, counties and mayors representing over 12 million residents.
Amicus Brief in Support of Plaintiffs-Appellees in Mayor & City Council of Baltimore v. B.P. p.l.c, by Michael Burger (September 2019)
Amicus brief filed by National League of Cities, the U.S Conference of Mayors; and the International Municipal of Lawyers Association in support of plaintiff-appellee and affirmance.
Local Government Amicus Brief in City of Oakland v. BP by Michael Burger (March 2019)
The Sabin Center filed an amicus brief on behalf of a local government coalition in support of Oakland and San Francisco’s demands that oil and gas companies mitigate the harm caused by rising sea levels, increasingly frequent and severe storms, and other climate impacts in their cities. The coalition members include the U.S. Conference of Mayors, the National League of Cities, and the International Municipal Lawyers Association.
Local Government Amicus Brief in California v. EPA by Michael Burger and Jessica Wentz, and related Press Release (February 2019)
The Sabin Center filed an amicus brief on behalf of a local government coalition in the lawsuit challenging the Trump administration’s revised determination that the GHG and fuel economy standards for light-duty vehicles are too stringent and should be weakened. The brief highlights the importance of the standards to cities and counties across the country and provides a local government perspective on why EPA’s decision is unlawful. The coalition members include the U.S. Conference of Mayors (USCM), the National League of Cities (NLC), and sixteen individual cities and counties that are home to more than 22 million people.
See also: Local Government Motion for Leave to Participate as Amici Curiae in California v. EPA and related Press Release (September 2018)
Amicus Brief in Support of Plaintiffs-Appellees in County of San Mateo v. Chevron Corp. by Michael Burger and Ama Francis (January 2019)
The Sabin Center, together with the Columbia Environmental Law Clinic, submitted an amicus brief on behalf of a local government coalition in the lawsuit brought by San Mateo County and other California cities and counties against fossil fuel companies seeking compensation for the costs of adaptation to sea level rise and other climate change impacts. The coalition members include the National League of Cities, the U.S. Conference of Mayors, and the International Municipal Lawyers Association.
Amicus Brief in support of appeal in New York City v. BP p.l.c. by Michael Burger and Jennifer Danis (November 2018)
The Sabin Center, together with the Columbia Environmental Law Clinic, submitted an amicus brief on behalf of a local government coalition in New York City’s lawsuit against fossil fuel companies seeking compensation for climate change-related harms and the costs of adaptation. The coalition members include the National League of Cities, the U.S. Conference of Mayors, and the International Municipal Lawyers Association.
Local Government Motion for Leave to Participate as Amici Curiae in California v. EPA by Michael Burger, Jessica Wentz, and Dena Adler, and related Press Release (September 2018)
The Sabin Center submitted a motion on behalf of a local government coalition for leave to participate as “amici curiae” (friends of the court) in the lawsuit challenging the Trump Administration’s decision to revisit the greenhouse gas emission and fuel economy standards established for light-duty vehicles. The coalition members include the U.S. Conference of Mayors (USCM), the National League of Cities (NLC), and sixteen individual cities and counties.
Joint Summary of the Amicus Curiae In Re: National Inquiry on the Impact of Climate Change on the Human Rights of the Filipino People, related Press Release (March 2018)
This brief consolidates and summarizes the key messages and arguments contained in the amicus curiae briefs submitted by legal scholars, experts, and human rights practitioners in support of the petitioners in the Philippines carbon majors case. Michael Burger and Jessica Wentz made contributions based on the amicus brief they submitted in 2016.
Appeal in the D.C. Circuit Court of Appeals in Physicians for Social Responsibility, et al. v. Pruitt by Michael Burger. The reply brief is available here. (November 2019)
The Sabin Center filed an appeal in the D.C. Circuit Court of Appeals in Physicians for Social Responsibility, et al. v. Pruitt. In this case, Michael Burger is working with the Columbia Environmental Law Clinic to represent two scientists who have challenged EPA's policy banning scientists with EPA grants from the agency's science advisory committees.
See also: Complaint Challenging Scott Pruitt’s Science Advisory Committee Directive, Columbia Environmental Law Clinic and Earthjustice, related Press Release (December 2017)
In this case, executive director Michael Burger is working with Columbia Environmental Law Clinic as a volunteer attorney to represent independent scientists Robyn Wilson and Joseph Arvai. This lawsuit challenges Scott Pruitt’s directive barring highly qualified, independent scientists from EPA’s science advisory boards.
Amicus Brief on Carbon Capture and Storage Technologies, Michael Burger and Jessica Wentz, and related Press Release (December 2016)
This amicus brief was written on behalf of eleven carbon capture and storage (“CCS”) experts in support of EPA’s emission standard for new coal-fired power plants. The standard is based on the CO2 emission reductions that can be achieved through the implementation of partial CCS, and one of the central issues in the case is whether CCS technologies are adequately demonstrated and available for installation at coal-fired power plants. The brief contains ample evidence corroborating EPA’s determination that these technologies are an adequately demonstrated system of emissions reduction for new coal-fired power plants.
Submission to Philippines Carbon Majors Investigation by Michael Burger and Jessica Wentz (December 2016)
This is a submission to the Philippines Commission on Human Rights in support of a petition submitted by Greenpeace Southeast Asia and the Philippine Rural Reconstruction Movement requesting an investigation into the responsibility of the “Carbon Majors” for human rights violations resulting from the impacts of climate change. The submission outlines the various ways in which climate change interferes with the enjoyment of human rights in the Philippines and around the world, and explains why the private companies can and should be held accountable for human rights violations arising from their contribution to climate change.
Clean Power Plan Amicus Brief by Michael Burger and Justin Gundlach, and related Press Release (April 2016)
More than 50 city and county governments from 28 states, together with The U.S. Conference of Mayors (USCM), the National League of Cities (NLC), and the mayors of Dallas, Knoxville, and Orlando have signed an amicus brief explaining why the U.S. Environmental Protection Agency’s Clean Power Plan is critical to the safety and economic security of local communities across the United States. The brief was authored by the Sabin Center for Climate Change Law at Columbia Law School.
See also: Amicus Motion on Behalf of Cities in Support of EPA’s Clean Power Plan by Michael Burger and Justin Gundlach, December 2015
Written Testimonies
- Testimony of Romany Webb before the Senate of Canada Standing Committee on Fisheries and Oceans Hearing on Ocean Carbon Sequestration and its Use in Canada, December 5, 2024
- Direct Testimony of Gregory Bruns in Support of the Clear Mountain Energy Center, September 3, 2024
- Direct Testimony of Gregory Vestring in Support of the Clear Mountain Energy Center, September 3, 2024
- Direct Testimony of Ethan Robertson in Support of Frasier Solar, August 14, 2024
- Direct Testimony of Bruce Beery in Support of Richwood Solar, July 19, 2024
- Direct Testimony of Ashley Beery in Support of Richwood Solar, July 19, 2024
- Direct Testimony of Dr. John Boeckl in Support of Oak Run Solar, May 10, 2023
- Third-party intervention in the case of Verein KlimaSeniorinnen and others v Switzerland at the European Court of Human Rights, December 5, 2022
- Written Testimony of Amy Turner before the New York City Department of Buildings, November 14, 2022
- Written Testimony of Amy Turner before New York City Council Committee on Environmental Protection Hearing on Building Electrification and Intro. 2317, November 17, 2021
- Written Testimony of Romany Webb before the Massachusetts Senate Committee on Global Warming and Climate Change: Hearing on Climate Resilience of Transportation and Electric Infrastructure, October 4, 2021
- Michael Gerrard's Testimony to Congress about Siting Renewable Energy on Public Lands, May 2019
- Written Statement of Michael H. Burger, Executive Director, on Climate Change and Human Rights, UPR Civil Society Consultation (February, 2015)
- Advance Written Statement of Michael H. Burger, Executive Director, on Climate Change and Human Rights, UPR Town Hall & Civil Society Consultation (July, 2015)
Submissions in Agency Rulemaking
- Comments on the Proceeding on Motion of the [New York State] Commission Concerning Electric Utility Climate Vulnerability Studies and Plans (submitted on August 30, 2024)
- Comments on New York Power Authority's 2024 Conferral Process (submitted August 13, 2024)
- Comments on Michigan Public Service Commission's Draft Application Instructions and Procedures for Renewable Energy and Energy Storage Facility Siting (submitted July 15, 2024)
- Comments on the Public Utilities Commission of the State of California's request for response on Order Instituting Rulemaking to Update Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems (July 8, 2024)
- Comments on EPA's Notice of Permit Application for the Woods Hole LOC-NESS Ocean Alkalinity Enhancement Project (submitted July 3, 2024)
- Comments on the National Science Foundation's Request for Information on Development of a Marine Carbon Dioxide Removal Research Plan (submitted April 18, 2024)
- Comments on DOE's Notice of Proposed Rulemaking on National Environmental Policy Act Implementing Procedures Regarding Categorical Exclusions (submitted December 28, 2023)
- Comments on CEQ's Notice of Proposed Rulemaking on National Environmental Policy Act Implementing Regulations Revisions Phase 2 (submitted September 28, 2023)
- Comments on BOEM's Notice of Proposed Rulemaking on Risk Management and Financial Assurance for OCS Lease and Grant Obligations (submitted August 28, 2023)
- Comments on BLM's Notice of Proposed Rulemaking on Conservation and Landscape Health (submitted June 26, 2023)
- Comments on CEQ's Interim Guidance on Consideration of Greenhouse Gas Emissions and Climate Change in NEPA agency reviews (submitted April 10, 2023)
- Comments on FERC's Notice of Proposed Rulemaking on Applications for Permits to Site Interstate Electric Transmission Facilities (submitted April 4, 2023)
- Comments on New York State - Department of Financial Services' Proposed Guidance for New York State Regulated Banking and Mortgage Institutions Relating to Management of Material Financial Risks from Climate Change (submitted March 20, 2023)
- Joint Comment Letter with the Environmental Defense Fund on the FAR Council's Proposed Rule on the Disclosure of GHG Emissions and Climate-Related Financial Risk (submitted February 13, 2023)
- Comments on the FAR Council's Proposed Rule on the Disclosure of GHG emissions and Climate-Related Financial Risk (submitted February 1, 2023)
- Comments on the draft Fifth National Climate Assessment (submitted January 27, 2023)
- Joint Comment Letter with CCSI on the EPA's Request for Information on Low Emissions Electricity Program & GHG Corporate Reporting (submitted January 18, 2023)
- Joint Letter to the New York State Department of Taxation and Finance's Acting Commissioner Amanda Hiller encouraging publication of the Solar and Wind Appraisal Model through the State Administrative Procedure Act process (submitted December 6, 2022)
- Comments on the Commodity Futures Trading Commission’s Request for Information on Climate-Related Financial Risk (submitted October 7, 2022)
- Comments on FERC's Notice of Proposed Rulemaking on One-Time Informational Reports on Extreme Weather Vulnerability Assessments Climate Change, Extreme Weather, and Electric System Reliability (submitted August 30, 2022)
- Comments on SEC's Proposed Rule on The Enhancement and Standardization of Climate-Related Disclosures for Investors (submitted June 17, 2022)
- Comments on FERC's Draft Policy Statement of Certification of New Interstate Natural Gas Facilities and Draft Policy Statement on Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews (submitted April 25, 2022)
- Comments of Sabin Center, EDF, and NJCF to NJBPU Gas Capacity Proceeding (submitted February 8, 2022)
- Comments on the Occupational Safety and Health Administration’s Advance Notice of Proposed Rulemaking on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (submitted December 14, 2021)
- Comments on the Michigan Public Service Commission's request for comments on improving utilities' preparedness for climate change impacts (submitted September 24, 2021)
- Comments on the White House Office of Science and Technology Policy's Request for Information to Improve Scientific Integrity Policies (submitted July 28. 2021)
- Comments on EPA's Proposal to Rescind the Safer Affordable Fuel Efficient Vehicles Rule Part One (submitted July 6, 2021)
- Comments on Petition to New York PSC to Comprehensively Study the Impacts of Climate Change on Utility Infrastructure (submitted June 28, 2021)
- Comments on petitions for review of orders of the FERC (submitted June 22, 2021)
- Comments in response to SEC's request for information on climate change disclosures (submitted June 11, 2021)
- Comments on NHTSA's Proposed Repeal of the Safer Affordable Fuel-Efficient Vehicles Rule Part One (submitted June 11, 2021)
- Supplemental Comments on FERC's Notice of Inquiry on its Certification of New Interstate Natural Gas Facilities (submitted May 26, 2021)
- Comments on the New York Public Service Commission's proposal to require climate-related risk disclosures by utilities (submitted Dec. 9, 2020)
- Comments on Proposed Regulations of the New York State Office of Renewable Energy Siting (submitted December 2, 2020)
- Attachment: New York State Decarbonization Pathways Analysis
- Comments on DOE's Proposed Revisions to its NEPA Regulations (submitted June 1, 2020)
- Comments on EPA's Proposed Strengthening Transparency in Regulatory Science Rule (submitted May 18, 2020)
- Comments on Proposed NEPA Regulations (submitted March 10, 2020)
- Comments on EPA's Proposed Revisions to the Oil and Gas New Source Performance Standards (submitted November 22, 2019)
- Comments on EPA’s Proposed Revisions to the Power Sector New Source Performance Standards (submitted March 18, 2019)
- Comments on EPA’s Proposed Revisions to the Oil and Gas New Source Performance Standards (submitted November 30, 2018)
- Comments on FERC’s Section 206 Inquiry on PJM Interconnection’s Open Access Transmission Tariff (submitted October 1, 2018)
- Comments on Proposed Amendments to Endangered Species Act (ESA) Regulations (submitted September 24, 2018)
- Comments on FERC’s Notice of Inquiry on its Certification of New Interstate Natural Gas Facilities (submitted June 18, 2018)
- Comments on EPA’s Proposed Repeal of the Clean Power Plan (submitted April 18, 2018)
- Comments on FERC’s Review of Grid Resilience in Regional Transmission Organizations and Independent System Operators (submitted April 13, 2018)
- Comments on BLM’s Proposed Revisions to the Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule (submitted March 26, 2018)
- Comments on EPA’s Notice of Data Availability Issued in Support of its Proposed Two Year Stay of the Oil and Gas New Source Performance Standards (submitted December 7, 2017)
- Comments on BLM’s Proposed Suspension of the Methane Waste Rule (submitted November 6, 2017)
- Comments on DOE’s “Grid Resiliency Pricing Rule” (submitted October 18, 2017)
- Comments on EPA’s Proposed Two Year Stay of the Oil and Gas New Source Performance Standards (submitted August 8, 2017)
- Comments on DOI’s Request for Input on Regulations to Repeal, Replace, or Modify Pursuant to Executive Order 13777 (submitted July 26, 2017)
- Comments on Proposed Amendments to Part 617 Regulations under the New York State Environmental Quality Review Act (submitted May 17, 2017)
- Comments on EPA’s Request for Input on Regulations to Repeal, Replace, or Modify Pursuant to Executive Order 13777 (submitted May 10, 2017)
- Comments on Proposed Sea Level Rise Projections for New York City, 6 NYCRR Part 490 (submitted December 19, 2016)
- Comments on the Federal Highway Administration’s Plan to Develop a Greenhouse Gas Performance Metric for National Highway Assessments (submitted August 18, 2016)
- Comments on the Federal Energy Regulatory Commission (FERC)’s Draft Guidance Manual for Environmental Report Preparation for Applications Filed Under the Natural Gas Act (submitted February 23, 2016)
- Comments on the Council on Environmental Quality (CEQ)’s Revised Draft Guidance on the Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in NEPA Reviews (submitted March 24, 2015)
- Comments on the Revised Proposed 6 NYCRR Part 570 – Regulation of Liquefied Natural Gas Facilities (submitted November 12, 2014)
- Comments on the New York State Department of Public Service’s Long Island Utility 2.0 Plan (submitted November 11, 2014)
- Submission of Jennifer Danis Comments for FERC's Technical Conference on Greenhouse Gas Mitigation: Natural Gas Sections 3 and 7 Authorizations, November 12, 2021
- Comments in response to FERC's Supplemental Notice on the Technical Conference Discussing Climate Change, Extreme Weather, & Electric System Reliability (submitted September 27, 2021)
- Comments on issues raised in FERC's Supplemental Notice of Technical Conference on Climate Change, Extreme Weather and Electric System Reliability (submitted Apr. 15, 2021)
Comments on Environmental Review Documents
- Comments on the Draft Environmental Impact Statement for the Proposed Pebble Project (submitted July 1, 2019 in collaboration with the Emmett Institute on Climate Change and the Environment at the UCLA School of Law)
- Comments on the Proposed Coastal Plain Oil and Gas Leasing Program in the Arctic National Wildlife Refuge (ANWR) (submitted March 13, 2019)
- Comments on the Notice of Intent to Prepare an Environmental Impact Statement for the Proposed 2019 Beaufort Sea Lease Sale in the Beaufort Sea Planning Area (submitted January 3, 2019)
- Comments on the Scope of the EIS for the Proposed Coastal Plain Oil and Gas Leasing Program in the Arctic National Wildlife Refuge (submitted June 19, 2018)
- Comments on the Bureau of Ocean Energy Management’s Call for Information and Nominations for Proposed 2019 Lease Sale in the Beaufort Sea Planning Area (submitted May 30, 2018)
- Comments on the Bureau of Ocean Energy Management’s 2019-2024 OCS Oil & Gas Leasing Draft Proposed Program and the Notice of Intent to Prepare a Programmatic Environmental Impact Statement (submitted March 9, 2018)
- Comment on FERC’s Draft Supplemental EIS for the Southeast Market Pipelines Project (submitted November 17, 2017)
- Attachment: Burger & Wentz (2017)
- Objection to the U.S. Forest Service’s Decision to Implement the Proposed Action Alternative in the Supplemental Final EIS for Federal Coal Lease Modifications COC-1362 & COC-67232 (West Elk Coal Mine) (submitted October 23, 2017)
- Comments on the U.S. Forest Service’s Supplemental Draft EIS for Federal Coal Lease Modifications COC-1362 & COC-67232 (West Elk Coal Mine) (submitted June 28, 2017)
- Comments on the U.S. Army Corps of Engineer’s Draft EIS for the Millinnieum Bulk Coal Terminal in Longview (submitted November 29, 2016)
- Comments on the Bureau of Land Management’s Proposed Greater Mooses Tooth Development Project (submitted August 19, 2016)
- Comments on the Bureau of Land Management’s Programmatic Review of the Federal Coal Leasing Program (submitted July 26, 2016)
- Comments on the Bureau of Ocean Energy Management (BOEM)’s Draft EIS for the Proposed 2017-2022 OCS Oil and Gas Leasing Program (submitted May 2, 2016)
- Comments on the U.S. Forest Service’s Supplemental Draft Environmental Impact Statement for the Proposed Exception to the Colorado Roadless Rule (submitted January 15, 2016)
- Comments on the Bureau of Ocean Energy Management’s 2017-2022 OCS Oil & Gas Leasing Draft Proposed Program and the Scope of the Programmatic Environmental Impact Statement (submitted March 30, 2015)
- Comments on FERC's Notice of Intent to Prepare an Environmental Impact Statement for the Delta LNG and Delta Express Pipeline Project (submitted November 14, 2019)
- Attachment: Burger and Wentz (2019)
- Comments on FERC's Notice of Intent to Prepare an Environmental Assessment Statement for the Planned Port Arthur LNG Expansion Project (submitted November 11, 2019)
- Attachment: Burger and Wentz (2019)
- Comments on FERC's Draft Environmental Impact Statement for the Planned Alaska LNG Project (submitted October 3, 2019)
- Attachment: Burger and Wentz (2019)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Planned Pointe LNG Project(submitted March 7, 2019)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Planned Commonwealth LNG Project (submitted March 26, 2018)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Planned Fourchon LNG Project (submitted December 5, 2017)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Planned Alaska LNG Project(submitted November 12, 2015)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement fo the Planned Jacksonville LNG Project(submitted March 30, 2015)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Planned Calcasieu Pass LNG Project (submitted February 19, 2015)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Planned Downeast LNG Import-Export Project (submitted Oct. 27, 2014)
- Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Proposed Mississippi River LNG Project (submitted October 27, 2014)
- Comments on Bureau of Ocean Energy Management's Draft Environmental Impact Statement for Empire Offshore Wind (submitted January 15, 2023)
- Comments on the Draft Scoping Document for the South Battery Park City Resiliency Project's Environmental Impact Statement (October 27, 2021)
- Comments on the Notice of Intent to Prepare an Environmental Impact Statement for the Hackberry Storage Project (submitted September 23, 2021)
- Comments on Supplement to the Draft Environmental Impact Statement for Vineyard Wind LLC’s Proposed Wind Energy Facility Offshore Massachusetts (submitted on July 27, 2020)
- Comments on the Draft Environmental Assessment for the JFK Proposed North Cargo Redevelopment Project (submitted November 26, 2018)
- Comments on draft environmental assessment for JFK airport runway reconstruction (submitted October 29, 2018)
- Comment on the Draft Scope of Work for the Environmental Impact Statement (EIS) for the New York City Borough-Based Jail System (submitted October 14, 2018)
- Comments on review of marine protected areas pursuant to Exec. Order 13795 (submitted July 25, 2017)
- Comments on scope of Draft EIS for project in Long Beach, NY (submitted July 17, 2017)
- Comments on the Draft Nationwide Programmatic EIS for the National Flood Insurance Program (submitted June 1, 2017)
- Comments on the Draft EIS for the New Rochelle Comprehensive Plan (submitted March 31, 2016)
- Comments on the Draft EIS for the Greater Moriches Comprehensive Zoning Re-Evaluation Study (submitted March 18, 2016)
- Comments on the Kingston Waterfront Brownfield Opportunity Area Plan (submitted March 9, 2015)
- Comments on the Former Sunbelt Equipment Brownfield Cleanup Program Application and Draft Remedial Action Work Plan(submitted March 6, 2015)
- Comments on the Water Authority of Great Neck North Storm Mitigation Project (submitted February 3, 2015)