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Recent Projects

  • Public Comments

    Comments to FERC on Seasonal Capacity Markets and Electricity Demand

    July 12, 2018

    PJM Interconnection (PJM), the electric grid and wholesale market operator in 13 states and Washington D.C., currently has a market design that leads to over-procurement of electric generating capacity, particularly from generation resources that are able to provide capacity throughout the year. This inefficient market design raises capacity costs and suppresses the participation of resources, such as wind, solar, and natural gas, whose generating capacity varies by season. The Federal Energy Regulatory Commission (FERC) recently held a technical conference to seek feedback on how PJM can redesign its capacity market to better facilitate participation of these seasonal resources. Our comments to FERC argue that replacing or supplementing the current annual-only capacity product with seasonal capacity products would improve the efficiency of the PJM capacity market. In addition, we suggest changes in the capacity market participation rules for wind, solar, and other intermittent resources.

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  • Public Comments

    Environmental Value of Distributed Energy Resources for New York State - Subgroup Report

    July 9, 2018

    New York State is seeking to refine its method for compensating distributed energy resources (DERs) based on the value that they provide, including their potential to reduce local air pollution and greenhouse gas emissions. Together with a group of government agencies, non-governmental community and environmental organizations, academic centers, and clean energy businesses, we submitted a report that describes the work of an informal, stakeholder-led Environmental / Environmental Justice Value Subgroup, which was formed to identify methods for calculating the environmental and public health value of avoided air pollution caused by DER injections in New York State. As part of that filing, we also submitted our report, Valuing Pollution Reductions, which serves as a general guide for state regulators interested in calculating the environmental and public health value of avoided air pollution caused by DER injections.

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  • Court Filings

    Brief on Repeal of Interior’s Valuation Rule

    June 25, 2018

    In 2016, the Department of the Interior’s Office of Natural Resources Revenue (ONRR) issued the Consolidated Federal Oil & Gas and Federal & Indian Coal Valuation Reform (Valuation Rule). The Valuation Rule sought to ensure that states and the federal government receive the full value of royalties due under the law for oil, gas, and coal extracted from public land. In 2017, ONRR abruptly reversed course and repealed the rule. State attorneys general have now sued ONRR over the repeal and filed a motion for summary judgment. In our brief supporting the plaintiffs, we argue that ONRR did not provide a reasoned explanation for repealing the Valuation Rule, both because ONRR fails to accurately assess the repeal’s economic impact and because ONRR fails to provide a reasoned explanation for its abrupt change in course.

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  • Public Comments

    Comments to BLM on Potential Oil and Gas Leasing in Arctic National Wildlife Refuge

    June 19, 2018

    As the Bureau of Land Management (BLM) considers opening Alaska’s Arctic National Wildlife Refuge for oil and gas leasing, pursuant to language in the 2017 Tax Act, our comments explain that development of oil and gas in the Arctic Coastal Plain would pose serious threats to this delicate, pristine ecosystem. In preparing an Environmental Impact Statement (“EIS”) for this potential lease sale, BLM must consider the many factors that weigh strongly against any leasing or development in the Refuge.

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  • Public Comments

    Comments to Interior’s Royalty Policy Committee

    June 6, 2018

    Our policy director, Jayni Hein, published a new op-ed in U.S. News & World Report on the Interior Department’s failure to protect the public interest in fossil fuel leasing decisions. In addition, she submitted the op-ed as public comments to Interior’s Royalty Policy Committee and gave verbal remarks at its meeting on June 6, 2018. Hein argues that Interior is required by law to earn “fair market value” for the use and development of public natural resources, and that providing royalty rate reductions and other undue concessions would inappropriately transfer public revenue to fossil fuel industry stakeholders.

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  • Public Comments

    Comments to New York on Offshore Wind Program

    June 4, 2018

    New York State is considering setting a procurement goal of 2,400 MWs worth of new offshore wind generation facilities by 2030. In our comments to the New York Public Service Commission, we encourage the Commission to continue the use of the Social Cost of Carbon to value the benefits of avoiding greenhouse-gas emissions in the state’s Offshore Wind Policy. We also explain that the proposal to pay for the benefits of offshore wind outside of the wholesale markets is a reasonable way to move closer to internalizing the external costs of carbon-dioxide emissions and other pollution.

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  • Public Comments

    Comments to California on Regulating Greenhouse Gas Emissions from Vehicles

    May 31, 2018

    EPA has indicated that it intends to weaken its emission standards for light-duty vehicles and that it may attempt to revoke California’s ability under the Clean Air Act to maintain these protective standards. Our comments to California’s Air Resources Board (CARB) discuss the substantial economic benefits that California would gain from maintaining the more stringent standards that both EPA and California currently require. We submitted our report, Analyzing EPA’s Vehicle-Emissions Decisions, to CARB to provide additional information on why weakening vehicle emission standards set for years 2022-2025 would be economically irrational.

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  • Public Comments

    Comments to New York on Electricity Rate Design

    May 29, 2018

    New York State is in the process of reforming its payment system for distributed energy resources (DERs), such as rooftop solar panels, away from a net energy metering policy that compensated these resources at retail electricity rates. Our comments to the New York Public Service Commission encourage the state to move towards rate designs that better reflect the underlying costs of generating, transmitting, and distributing electricity, including environmental externalities for all customers, including those who do not own DERs. Our joint comments with other stakeholders also offer high-level principles for rate design that can help achieve the state’s clean energy goals.

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  • Public Comments

    Oral Comments to EPA’s Science Advisory Board

    May 25, 2018

    EPA’s Science Advisory Board provides independent scientific guidance to the Agency. Our oral comments to EPA’s Science Advisory Board encourage the Board to review the science and economics behind EPA’s proposed deregulatory actions. We ask the Board to consider our recent paper on the full value of reducing particulate matter (PM) pollution in evaluating the benefits of reducing PM below the current National Ambient Air Quality Standards. Our comments also ask the Board to review EPA’s manipulation of economics in order to downplay the climate harms of its deregulatory actions. Specifically, we discuss manipulations of the 2016 Interagency Working Group’s Social Cost of Carbon estimates. We argue that EPA’s new “interim” estimate for the Social Cost of Carbon ignores the global nature of climate damage and obscures the devastating effects that climate change will have on future generations, and we strongly encourage review of the methods used to reach this new “interim” estimate.

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  • Court Filings

    Expert Declaration on Using the Social Cost of Carbon in Environmental Assessments

    May 25, 2018

    Fossil fuel development causes significant harm to the environment and human health, and our work continues to push for public disclosure of these harms. Dr. Peter Howard, our economics director, submitted a declaration on the environmental, public health, and social welfare costs of two resource management plans finalized in 2015 by the Bureau of Land Management (BLM) in Montana and Wyoming. Part of a suit against BLM by the Western Organization of Resource Councils, this declaration was presented alongside declarations from other noted climate experts, including Dr. James Hansen. Dr. Howard found that the air pollution and greenhouse gases emitted during the extraction, processing, transportation, and combustion of 11 billion tons of coal and oil and gas from thousands of wells at these two regions will cause more than $802 billion in damages between 2018 and 2028.

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