Institute for Policy Integrity logo

Twitter @policyintegrity

Recent Projects

  • Reports

    Capacity Markets and Externalities

    April 30, 2018

    Many states are taking action on climate change by paying zero- and low-emitting electricity generators for avoiding the emissions that fossil-fuel-fired resources would otherwise emit. These “externality payments” help level the playing field between emitting and non-emitting generators. Critics of these policies argue that these payments might negatively affect the efficiency of wholesale electricity markets by reducing capacity prices, which heavily affect how generators enter and exit the market.

    Our report shows why the premises underlying recent reforms, which seek to shield capacity markets from the potential price impact of pollution externality payments, are flawed. The report argues that redesigning capacity markets in reaction to these state policies shows concern for only private generation costs and disregards the fact that externality payments help correct market failures associated with air pollution, improving economic efficiency.

    Rushed market design changes based on the unsupported assumption that state policies negatively affect capacity markets may actually harm the functioning of the markets, while potentially undoing states’ efforts to combat pollution and climate change.

    Read more

  • Public Comments

    Comments on Proposed Repeal of the Clean Power Plan

    April 26, 2018

    As the Environmental Protection Agency (EPA) continues its rulemaking to repeal the Clean Power Plan, we submitted two sets of comments that challenge EPA’s legal and economic arguments for undoing this important climate policy.

    Read more

  • Reports

    Managing the Future of Energy Storage

    April 24, 2018

    Many policymakers assume that increasing deployment of energy storage will automatically reduce greenhouse gas emissions, in part by helping to integrate renewable energy resources with intermittent and variable generation. This report explores situations in which energy storage systems can in fact lead to increased emissions, and offers reforms to correct for poor incentives while ensuring that energy storage can provide the maximum benefit possible to the grid.

    Policy reforms that account for the range of benefits provided by storage, including reduced air pollution, are required at both state and federal levels. This report recommends that policymakers (1) focus on accurately pricing externalities caused by greenhouse gases; (2) eliminate entry barriers for energy storage systems; (3) and eliminate barriers that energy storage systems face to receiving multiple value streams for the various services they provide. The report outlines steps to realize each of these three goals and provides an overview of state and federal actions currently under way.

    Read more

  • Public Comments

    Comments on the Rescission of BLM’s Waste Prevention Rule

    April 23, 2018

    The Bureau of Land Management has proposed to rescind or revise its 2016 rule to limit methane emissions associated with natural gas production. The analysis for the original rule showed it to be hugely beneficial to the public, largely due to the avoided climate damages, for which BLM relied on the IWG’s Social Cost of Methane in the original analysis. Now, BLM has radically altered the analysis for the rule, claiming that the costs outweigh its benefits and the Bureau is justifying its decision to rescind or revise the rule based on this flawed rehashing of the effects, even though many of the problematic elements actually undercut BLM’s justification of the proposal to rescind or revise the rule. We submitted comments focused on this faulty analysis and also submitted joint comments on how BLM failed to appropriately value the Social Cost of Methane and other foregone benefits that would result from the rule’s rescission.

    Read more

  • Public Comments

    Comments on EPA’s Failure to Monetize Forgone Emission Reductions in CTG Withdrawal

    April 23, 2018

    EPA is soliciting comments on the proposed withdrawal of its control techniques guidelines (CTG) for the oil and natural gas industry. EPA supports its proposed withdrawal of the CTG with an analytical memorandum on avoided costs and forgone emission reductions. The agency monetizes the alleged avoided costs down to the dollar, but EPA fails to monetize the forgone emission reductions. Our joint comments illustrate how the proposed withdrawal’s costs outweigh its benefits, by applying the Social Cost of Methane to EPA’s quantified foregone emissions reductions. We argue that by only quantifying the volume of forgone methane reductions, instead of monetizing the associated damages to the environment, public health, and welfare, EPA obscures the very real and readily monetizable negative consequences of its proposed withdrawal.

    Read more

  • Public Comments

    Comments to OSMRE on Failure to Use the Social Cost of Greenhouse Gases in a Federal Mining Plan

    April 23, 2018

    We recently submitted comments to Office of Surfacing Mining Reclamation and Enforcement (OSM) on its environmental assessment (EA) on modifying the federal mining plan for Bull Mountains Mine No. 1 in Montana. The EA evaluates a proposal to extend operations at an existing mine by nine years, which would produce an extra 86.7 million tons of coal. While the EA quantifies the tons of greenhouse gas emissions related to the project, OSM refused to use the social cost of greenhouse gases metric to monetize the climate effects of these emissions. Our comments explain why the agency’s refusal is arbitrary and unlawful in light of a growing body of case law, which holds that failure to monetize a project’s costs is impermissible if an agency justifies an action based on the project’s monetized benefits. Our comments also explain why the social cost of greenhouse gases metric is appropriate for projects of this scale, why the metric’s use is not limited to rulemakings, and how failing to adequately account for the project’s climate effects is a violation of NEPA.

    Read more

  • Public Comments

    Comments to FERC on Failure to Monetize Climate Effects of Riverdale Gas Pipeline

    April 23, 2018

    We recently submitted comments to the Federal Energy Regulatory Commission on its environmental assessment (EA) for the Rivervale South to Market pipeline project in New Jersey. Once again, FERC quantified the tons of downstream greenhouse gas emissions that the project would generate, but the Commission did not use the social cost of greenhouse gases to monetize the climate effects of those emissions. In the EA, FERC incorrectly claims that it is impossible to determine the significance of a discrete amount of additional greenhouse gas emissions. Our comments dispel FERC’s arbitrary and misleading rationale and explain why failing to meaningfully analyze a project’s climate effects violates NEPA. Our comments also offer guidance for how the Commission should use the social cost of greenhouse gases metric based on the best available science and economics going forward.

    Read more

  • Public Comments

    Comments on California’s Distributed Energy Resources Policy

    April 13, 2018

    The California Public Utilities Commission (CPUC) is developing a comprehensive policy for integrating Distributed Energy Resource (DERs), like rooftop solar, into its energy system. A March 2018 administrative law judge ruling heavily cited our earlier comments in laying out a revised plan to require the state’s utilities to conduct a societal cost test to help compare the net benefits of different DER technologies. We submitted comments to the CPUC commending the agency for its revisions to the proposed analysis and recommending additional improvements.

    Read more

  • Academic Articles/Working Papers

    Environmental Standards, Thresholds, and the Next Battleground of Climate Change Regulations

    April 11, 2018

    Regulations to curtail climate change have the additional benefit of reducing air pollution by accelerating the shift away from carbon-intensive and high-polluting energy such as coal. The benefits from reducing just one air pollutant – particulate matter – account for almost half of the quantified benefits of the Obama Administration’s Clean Power Plan. Regulatory opponents have launched an aggressive attack on the use of these benefits to justify climate change regulations. They claim that these benefits are not real, are accounted for in other regulations, or should not be considered because they are indirect benefits. This Article collects and analyzes for the first time the robust support for valuing particulate matter and other air pollution reduction benefits. Following an examination of the scientific literature, longstanding agency practices under administrations of both major political parties, and judicial precedent, the authors conclude that particulate matter benefits deserve a meaningful role in regulatory cost-benefit analysis.

    Read more

  • Public Comments

    Comments to Virginia on Its Proposal to Join the Regional Greenhouse Gas Initiative

    April 9, 2018

    The State of Virginia is proposing to join the Regional Greenhouse Gas Initiative (RGGI), a carbon trading program currently including states across the Northeastern U.S. Including Virginia energy producers in RGGI will greatly expand the scope of the carbon market, thereby improving market efficiency, competitiveness, and lowering carbon abatement costs. Our comments to Virginia on its proposal offer two suggestions to ensure that Virginia’s addition to RGGI creates a competitive permit trading market.

    Read more