Institute for Policy Integrity

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Project Updates

Viewing all updates in Climate Change and Energy Policy
  • Public Comments

    Comments to New York State on Clean Energy Standards for Existing Generators

    January 8, 2018

    New York State plans to provide support to some existing small hydro, wind, and biomass generation facilities at risk of closure, in order to prevent the state from backsliding on its ambitious clean energy goals. The New York Public Service Commission released a report on the Clean Energy Standard Tier 2 Maintenance program, which focuses on the criteria a generator should meet in order to receive financial support and how these payments should be determined. Our comments on the report encourage the Commission to harmonize these payments across all proposed review processes for Tier 2 generators.

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  • News

    Presentation at the Association of American Law Schools

    January 5, 2018

    Our Litigation Director, Bethany Davis Noll, and Energy Policy Director, Burcin Unel, recently presented a draft paper on federal carbon pricing in wholesale energy markets at the 2018 Association of American Law Schools Conference. In a panel on legal constraints to implementing clean energy policies, they discussed the legal authority of the federal government, specifically the Federal Energy Regulatory Commission, to price carbon emissions in wholesale energy markets and how this authority interacts with state-level clean energy policy.

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  • Public Comments

    Comments to the U.S. Fish and Wildlife Service on Market-Based Mitigation Programs

    January 5, 2018

    We recently submitted comments to the U.S. Fish and Wildlife Service on its market-based mitigation programs. Our comments were based in part on the recommendations Integrity’s Legal Director, Jason Schwartz, made to the Administrative Conference of the United States on marketable permits, which were adopted in late December.

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  • Presentation to the New York Department of Public Service

    January 3, 2018

    The New York Department of Public Service (DPS) is working on developing a more accurate compensation mechanism for distributed energy resources (DERs) that can capture the true value that DERs create. We have been particularly involved in the Value Stack Working Group, which is examining possible ways to price DERs based on specific value components of the resources, including environmental attributes. We were invited to make a presentation to the PSC on monetizing externalities of air pollution. In our presentation, we explained that the Commission can increase economic efficiency by directly incorporating the monetary value of avoided emissions as a value stack component into the DER compensation mechanism, and provided a methodology for this process. We plan to remain involved in this proceeding as it progresses in the coming months.

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  • Court Filings

    Brief on the Bureau of Land Management’s Waste Prevention Rule

    December 22, 2017

    Our amicus brief to the United States District Court for the District of Wyoming defends the 2016 Bureau of Land Management’s “Waste Prevention Rule,” which is designed to limit methane waste from oil and gas production on public lands. In our brief, we show that the rule reasonably complied with BLM’s statutory duty to set waste-prevention rules that focus on private benefits to industry as well as on the health and environmental benefits of protecting natural public resources and the environment. We also argue that BLM’s approach to evaluating those health and environmental benefits of reducing methane emissions through the use of the Social Cost of Methane was reasonable and appropriate. The Social Cost of Methane is the best available metric for measuring damages from methane emissions. And it allowed BLM to set restrictions based on the global estimate of damages from methane emissions, which best advances U.S. interests and is consistent with BLM’s statutory mandate.

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  • Public Comments

    Comments on Arctic Drilling to the Bureau of Ocean Energy Management

    December 15, 2017

    We submitted comments on the Bureau of Ocean Energy Management’s environmental impact statement for potential offshore oil drilling and an undersea oil pipeline off Alaska’s northern coast. While expanded drilling in the Arctic presents many climate and public health concerns, BOEM did use the Social Cost of Carbon in assessing environmental impacts of the Liberty Development and Production Plan. . Our comments encourage BOEM to continue using the best available methods for the Social Cost of Carbon in future environmental impacts statements, and we also recommended that BOEM use the Interagency Working Group’s Social Cost of Methane to quantify methane damages.

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  • Public Comments

    Comments on EPA Methane Rule Stay

    December 15, 2017

    The Environmental Protection Agency (EPA) recently paused certain requirements to reduce methane leaks and emissions from new oil and gas facilities. In its “notice of data availability” for the proposed stay, EPA claims that the compliance costs of reducing these emissions exceed the benefits to the public and to industry. Our comments argue that EPA manipulated economics to make this claim. EPA undervalued the social cost of methane emissions and claimed that the forgone benefits of the rule are only $5.4 to 23 million per year, when EPA’s original estimates said the rule would create public benefits of $140-180 million per year.

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  • Public Comments

    Comments on Scope of Bill Impact Study to New York

    December 11, 2017

    New York State is carefully considering rate design reforms that could be adopted by utilities to provide efficient incentives for adoption of distributed energy resources. Studies on customer bill impacts of such rate design changes are necessarily going to be an important factor in moving forward. Our comments on the scope of bill impact studies emphasize that the effect on consumer bills is just one of the aspects to be considered when looking at rate design changes. In addition, we suggest that DPS give more guidance on the types of rate designs it’s considering, parameters used to model consumer behavior, and the time horizon that the studies cover.

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  • News

    Presentation to New York State Policymakers on Carbon Pricing

    December 11, 2017

    Bethany Davis Noll, our litigation director, and Dr. Jeffrey Shrader, our economics fellow, participated in a Technical Conference on carbon pricing in New York wholesale markets, hosted by the New York State Department of Public Service and the New York Independent System Operator. Davis Noll participated in the roundtable discussion on how best to address any potential leakage, expressed our support for efforts to address the issue, and discussed the legal implications of any such efforts. Shrader participated in the roundtable discussion on revenue allocation, expressed our support for carbon pricing as the most economically efficient and technology neutral way of internalizing climate damages from greenhouse gases, and discussed that there are many ways to use the revenue based on policy priorities as long as the revenue allocation does not undo the incentives carbon pricing creates.

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  • Letters

    Joint Letter to the House Committee on Natural Resources on the Social Cost of Carbon

    November 30, 2017

    We recently submitted a joint letter, coauthored by several environmental groups, to the House Committee on Natural Resources about the “Transparency and Honesty in Energy Regulations Act of 2017.” This act, H.R. 3117, seeks to direct agencies to ignore or drastically undervalue climate damages, and would seriously hamper future use and development of economically and scientifically sound estimates for the Social Cost of Carbon. This would result in federal government decisionmaking that fails to adequately account for the enormous social and economic consequences of climate change. In the letter, we urge the Committee to reject this and any other attempt to weaken, minimize or eliminate the requirement that agencies take into account the cost of climate change.

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