Project Updates – Energy and Environment

  • Friday
    December 19th,

    Energy Conservation Standards - Public Comments

    Policy Integrity has submitted comments to the Department of Energy, encouraging DOE to improve its economic justification for a proposed energy efficiency determination. DOE has determined that energy conservation standards for mercury vapor and metal halide high-­intensity discharge lamps are not “economically justified” as required by statute, even though such standards could save up to 1.6 quadrillion British thermal units of energy. By reducing electricity demand at and pollution from fossil fuel­-fired power plants, such energy savings would generate environmental and health benefits. However, at no point in DOE’s documentation does the agency discuss environmental and health benefits as part of its analysis of “economic justification” and “national impact.”

    The failure to consider these benefits is inconsistent with the agency’s practice in prior energy efficiency rulemakings. Given that the agency has a readily available methodology for quantifying and monetizing some of the key environmental and health benefits generated by energy savings, we suggest that the final determination should include such quantified benefits, whether or not they would change DOE’s final determination on whether the standards are cost-benefit justified.

    Our full comments are available here.


    Issue(s): Energy and Environment   Type: Public Comments

  • Monday
    December 1st,

    EPA’s Clean Power Plan - Public Comments

    In Policy Integrity’s recently submitted public comments on the EPA’s Clean Power Plan, we make the case that the EPA’s flexible, cost-minimizing approach to setting performance standards for existing power plants is consistent with over 30 years of EPA Clean Air Act practice, under both Republican and Democratic administrations. While opponents of the Clean Power Plan have argued that the EPA is taking unprecedented and unwarranted steps to regulate carbon dioxide under the Clean Air Act, we show that the plan is deeply rooted in precedent.

    Our comments discuss the many historical antecedents to the elements of the plan that opponents have criticized: the EPA’s use of statewide limits on emissions rates when the statute refers to limits on sources; the fact that this rule could shift the balance of fuels used to produce electricity; the use of demand-side energy efficiency measures in analysis of how states can meet the requirements of the Act; the use of performance standards to existing sources that are regulated under hazardous air standards; and the accounting for co-benefits, such as the reductions in harmful particulate matter that will occur in tandem with greenhouse gas reductions, in the rule’s cost-benefit analysis.

    We also address why the EPA’s approach is preferable to a strict, technology-based standard, and suggest some ways in which the EPA could make the program even more efficient.

    Issue(s): Energy and Environment   Type: Public Comments

  • Tuesday
    October 7th,

    Public Comments on Net Metering in Wisconsin

    Wisconsin is one of more than 40 states with a “net metering” law that allows solar-powered households to sell some of the electricity they generate back into the grid for a fixed price. The Wisconsin Electric Power Company and Wisconsin Gas LLC recently proposed changes to their net metering rates, arguing in part that the rates force them to fund additional grid maintenance and modernization without appropriate compensation. However, the current rates also do not account for the climate and public health benefits from distributed solar generation.

    Policy Integrity submitted comments to the Public Service Commission of Wisconsin, arguing that both the positive and negative externalities of distributed solar generation should be considered when determining net metering rates. Specifically, we suggest that the Commission should:

    • Adjust the proposed net metering rate to include the health and environmental benefits
      associated with the avoided greenhouse gas (GHG) emissions and emissions of local
    • Adjust the proposed net metering rate to include the value of the net impact of distributed
      solar generation on the local grid; and
    • Consider regulatory reforms to better achieve Wisconsin’s energy goals.

    The full comments are available here.

    Issue(s): Energy and Environment   Type: Public Comments

  • Friday
    September 26th,

    Oil Train Safety - Public Comments

    Driven by growth in the production of oil in the U.S. and Canada, there has been a significant increase in rail transportation of crude oil over the past five years, with a corresponding increase in the number of accidents. Many oil trains pass through sensitive environmental habitats and densely populated areas, and even share track with commuter trains in some regions.

    In 2013, more oil spilled from U.S. trains than in the previous four decades combined. These crude-by-rail accidents have resulted in serious damage to the environment as well as fatalities; 47 people died in the Lac-Mégantic, Quebec accident.

    Policy Integrity recently submitted public comments on proposed enhanced tank car standards and operational controls for “High-Hazard Flammable Trains” to the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration.

    In the interest of better protecting public safety and maximizing net benefits from the proposed rule, we suggest that the agency:

    • Explain the rationale for its selected timeline and alternatives, and consider additional options that would increase safety, such as phasing-out DOT-111 cars on an accelerated timeline;
    • Improve its calculation of costs and benefits by using the best available data, and fully account for co-benefits and countervailing risks;
    • Provide more detailed guidance on how to perform train routing analysis to maximize net benefits;
    • Collaborate with states to increase compliance with federal regulations; and
    • Collect more accurate data on accident causes, and continuously improve safety standards.

    Issue(s): Energy and Environment   Type: Public Comments

  • Friday
    September 12th,

    Livermore Argues Offshore Leasing Case in DC Circuit Court

    The government’s offshore leasing system fails to account for uncertainties about environmental harms—the system ignores “option value,” a well-established economic technique that quantifies the value of delaying decisions to acquire crucial information. As a result, the current leasing system leads to over-exploitation of natural resources and excessive environmental risk.

    A current lawsuit is challenging the use of this flawed economic analysis in the Bureau of Ocean Energy Management’s (BOEM’s) 2012-2017 leasing plan for the Gulf of Mexico and the Alaskan coast.

    The U.S. Court of Appeals for the D.C. Circuit heard the oral argument in Center for Sustainable Economy v. Jewell on September 11th. Policy Integrity senior advisor Michael Livermore represented the plaintiff, arguing that BOEM must consider option value to make the leasing system economically fair. The case could have significant implications for all government natural resource leasing programs. A ruling is expected in the coming months.

    The opening brief for the case is available here and the reply brief is available here. Audio of the oral argument is available here.

    Issue(s): Energy and Environment