Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

  • 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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  • Court Filings

    Federal Court Supports Use of Social Cost of Carbon

    August 8, 2016

    On August 8, 2016, the Seventh Circuit handed down its opinion in Zero Zone, Inc. v. United States Department of Energy, upholding the agency’s use of the social cost of carbon (SCC) in its regulatory impact analysis of commercial refrigerator energy efficiency standards. The ruling may have paved the way for a new chapter in economically efficient U.S. climate policies, and our brief for the case was acknowledged in the judges’ opinion.

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  • Court Filings

    Brief for Challenge to Ozone Standard

    August 5, 2016

    The U.S. Court of Appeals for the D.C. Circuit will soon hear arguments in Murray Energy Corp. v. U.S. E.P.A., challenging the EPA’s revised ozone National Ambient Air Quality Standards (NAAQS). Policy Integrity has submitted an amicus brief in support of the EPA for this case.

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  • News

    New York State Clean Energy Standard Final Order

    August 1, 2016

    In 2015, New York State announced its Clean Energy Standard, an ambitious mandate to boost clean energy. We have submitted numerous comments to the New York State Public Service Commission, suggesting several changes in the design of this Standard to ensure that the state’s policy goals can be met in the most-cost effective manner. In its final order, the Commission adopted several of our suggested changes. Most notably, the Commission relied on our comments in deciding to calculate zero-emission credit payments based on the Social Cost of Carbon. This marks a major success in our ongoing efforts to encourage government agencies to use the Social Cost of Carbon as a tool when designing policy.

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  • Public Comments

    New York State Zero-Emissions Attributes Comments

    July 22, 2016

    We recently submitted comments to the New York State Department of Public Service Staff regarding their Responsive Proposal for Preserving Zero-Emissions Attributes. This Proposal offers recommendations on how to achieve New York’s clean energy target: 50 percent of all electricity used in the state by 2030 should be generated by renewable energy sources.

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