Institute for Policy Integrity

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

    Comments to Massachusetts Department of Environmental Protection on Greenhouse Gas Reductions

    March 1, 2017

    The Massachusetts Department of Environmental Protection (“MassDEP”) has proposed a set of regulations to limit the greenhouse gas emissions from electric power plants, natural gas pipelines, government-owned transportation equipment, and utility-owned switchgear equipment. MassDEP has also proposed a new requirement that retail sellers of electricity purchase gradually increasing amounts of clean energy, along with non-binding targets for greenhouse gas emissions from the transportation sector.

    In our comments to MassDEP, we offer three suggestions to ensure these regulations cut global greenhouse gas emissions in a cost-effective way. First, we encourage MassDEP to prevent potential emissions leakage to other states in the Northeast’s Regional Greenhouse Gas Initiative (“RGGI”) program. Second, we recommend the regulations should be technology-neutral and use a flexible compliance system. Third, we recommend enforceable emissions limits on the transportation sector rather than non-binding targets, especially considering that the state’s emissions from transportation sector are almost twice those of the electric sector.

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  • Public Comments

    Energy Storage Comments to FERC

    January 30, 2017

    In November 2016, the Federal Energy Regulatory Commission (FERC) announced its intent to ease the process for energy storage and distributed energy resources to participate in wholesale electricity markets. The proposed rule would require regional transmission organizations (RTOs) and independent system operators (ISOs) to revise their tariffs to energy providers in order to promote technology neutrality. In comments on the rule, we recommend that in addition to adjusting these tariffs, FERC should take more steps to fully realize the benefits that these technologies could provide for wholesale markets. We recommend that the Commission explicitly clarify the benefits for which it compensates these technologies; allow states to compensate for distribution-side benefits; eliminate location-based constraints on resource participation while recognizing the importance of location in optimally dispatching these services; encourage coordination between RTOs/ISOs and state regulators; and promote advanced metering technology to increase efficiency in how energy is dispatched.

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  • Court Filings

    Brief for Challenge to EPA’s Carbon Standards for New Power Plants

    December 25, 2016

    The EPA’s Carbon Pollution Standards for New Power Plants limit carbon dioxide emissions from new, modified, and reconstructed plants. A group of state attorneys general and energy companies have filed suit challenging the standards on several grounds. Policy Integrity submitted an amicus brief in support of EPA.

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  • Public Comments

    Comments to California Air Resources Board on 2030 Target Scoping Plan Draft

    December 21, 2016

    This summer, California extended its greenhouse gas emissions reduction program to 2030 with two companion bills. The legislation modifies how the Air Resources Board (ARB), the state agency responsible for regulating air pollution, should assess proposed policy measures and prioritize goals in designing regulations. ARB staff released a preliminary draft of the scoping plan for how to meet the new 2030 targets in early December and is expected to release a second draft for comment in mid-January. We submitted comments on the December draft, making recommendations on how to structure the scoping plan’s economic analysis to best achieve the goals laid out in ARB’s new mandate.

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  • Public Comments

    Comments on Distributed Energy Valuation Methods in New York

    December 7, 2016

    The New York State Public Service Commission’s “Reforming the Energy Vision” initiative, an effort to modernize New York’s electricity policy, seeks to integrate distributed energy resources (DERs) into the state’s energy supply. The Commission sought proposals on how to compensate these producers of electricity for the full value that they provide to the electric grid. We submitted joint comments with the Environmental Defense Fund on an appropriate valuation methodology. We encourage the Commission to include the full range of environmental benefits of DER, such as reduced air pollution, and to ensure consistency across the Commission’s other programs and across all technologies. This work builds on our earlier comments on unbundling price signals to compensate DER for the time-based, locational, and environmental benefits they provide.

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  • Public Comments

    Comments on the Department of Energy’s Use of the Social Cost of Carbon

    December 1, 2016

    In a proposed set of energy efficiency standards for refrigeration systems and residential furnaces, the Department of Energy (DOE) used the Social Cost of Carbon (SCC) to value the climate benefits of more efficient technologies. DOE did not, however, incorporate this benefit for other greenhouse gases such as methane. We recently submitted joint comments with the Environmental Defense Fund, Natural Resources Defense Council, and Union of Concerned Scientists to reaffirm the use of the SCC. We also encourage the agency to monetize the benefits of other greenhouse gas reductions, such as through the existing Social Cost of Methane methodology; and to continue to update these estimates to reflect the latest science and economics on the costs of climate change damages.

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  • Public Comments

    Comments to EPA on the Clean Power Plan/Clean Energy Incentive Program

    October 31, 2016

    We recently submitted comments to the Environmental Protection Agency on the Clean Energy Incentive Program (“CEIP”). The CEIP is a voluntary early action program to help states move forward on Clean Power Plan compliance and energy market planning. Clean Power Plan opponents have argued that it is inappropriate for EPA to move forward on its CEIP guidance because the Supreme Court has stayed the Clean Power Plan.

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  • Public Comments

    Comments on New York State Clean Energy Standard Petitions

    October 31, 2016

    We recently submitted comments to the New York State Public Service Commission, responding to petitions for rehearing on the Clean Energy Standard. The Commission’s Clean Energy Standard created Zero-Emissions Credits for nuclear generation, compensating these zero-emissions generators through a valuation system based on the Social Cost of Carbon (“SCC”). Various parties submitted petitions for rehearing or clarification, and criticized the Order on a variety of grounds. Among other criticisms, challengers argue that it was inappropriate for the Commission to use the SCC to value the zero‐emission attributes of nuclear energy resources alone, and that other types of low‐ emitting resources (e.g., small hydro) should receive commensurate payments for their zero‐emission characteristics.

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  • Public Comments

    Comments on New York State Benefit Cost Analysis Handbooks

    September 26, 2016

    We recently submitted reply comments to the New York State Public Service Commission on Benefit Cost Analysis Handbooks submitted to the Commission by utility companies, within the Reforming the Energy Vision proceeding. Benefit-cost analysis will assist in determining the best resource allocations between traditional utility distribution grid investments and distributed energy resources (DER), by allowing for direct comparison. These Handbooks will help ensure that the utilities’ benefit-cost analyses will help to select investment options that will maximize net benefits to the public.

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  • Public Comments

    Comments on NARUC’s Distributed Energy Resources Compensation Manual

    September 2, 2016

    As distributed energy resources (DER) become more common and play a larger role in helping meet clean energy targets, many states are increasing their focus on the valuation and compensation of these resources. The National Association of Regulatory Utility Commissioners (NARUC) is creating a manual to assist states with these key policy questions. We recently submitted comments to NARUC’s Staff Subcommittee on Rate Design to help ensure that the manual is complete, accurate, and unbiased.

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