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Recent Projects

  • Reports

    No Turning Back

    October 26, 2018

    For 50 years, California has enjoyed unique authority to regulate air pollution from newly manufactured motor vehicles. While the Clean Air Act preempts all other states from setting their own vehicle emission standards, California can request a waiver to do so if it determines that its standards are at least as protective of public health and welfare as federal standards issued by the U.S. Environmental Protection Agency (“EPA”). Once a waiver is granted, other states can adopt California’s more stringent vehicle emissions standards as their own.

    Since the waiver provision was enacted in 1967, EPA has granted more than 50 waivers for California, fully denied only one (a decision it subsequently reversed), and revoked zero. EPA has now proposed to withdraw the waiver California received in 2013 to set its own greenhouse gas emission standards, in conjunction with a weakening of federal greenhouse gas emission standards for vehicles in model years 2021 through 2026.

    Because a waiver withdrawal would be entirely unprecedented, neither courts nor legal scholars have previously had cause to discuss the circumstances, if any, under which a waiver might permissibly be withdrawn. This report analyzes whether EPA possesses revocation authority and, assuming it exists at all, when and how such authority may be exercised. It is an update to the August 2018 version of the same report.

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  • Public Comments

    Comments to the California Air Resources Board on its Cap-And-Trade Program

    October 22, 2018

    The California Air Resources Board (ARB) is extending and changing its cap-and-trade program for greenhouse gases. We recently submitted comments that outline ways the ARB can improve its proposed updates.

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  • Public Comments

    Comments on New Jersey’s Energy Master Plan

    October 15, 2018

    New Jersey is revising its Energy Master Plan (EMP) for 2019. In advance of the first draft of the plan, the New Jersey Board of Public Utilities, along with other state agencies, formed a committee to engage with stakeholders on the contours of the new plan. We submitted comments to the EMP Committee with a number of recommendations. Specifically, in drafting the 2019 EMP, we advise the Committee to consider grid resilience in a holistic manner and apply cost-benefit analysis to resilience plans and investments; adopt a granular approach to rate design, rather than use net metering; and design an incentive structure for energy storage operators to ensure that the use of energy storage systems reduces greenhouse gas emissions. These recommendations draw upon several of our recent publications on electricity policy, including reports on grid resilience and energy storage, and an academic article, also on energy storage. The first draft of the EMP is scheduled to be released this winter.

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  • Public Comments

    Expert Testimony on Colorado’s Low Emission Vehicle Program and the Social Cost of Carbon

    October 12, 2018

    We recently submitted expert testimony on the benefits of Colorado’s proposed Low Emission Vehicle Program. The LEV program could avoid millions of tons of greenhouse gas emissions, and we explain to the Colorado Air Quality Control Commission the importance of and methodology for monetizing the real-world contributions of those emissions to global climate change. Our report shows, by applying Social Cost of Carbon estimates, that Colorado’s proposed LEV program could generate billions of dollars’ worth of climate benefits.

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  • Public Comments

    Comments to the California PUC on Energy Storage

    September 26, 2018

    We recently submitted comments to the California Public Utilities Commission on the Self-Generation Incentive Program (SGIP). Retrospective review of SGIP has found that, contrary to the program’s goals, greenhouse gas emissions sometimes increase when energy storage systems are deployed. To address this unintended consequence, the CPUC Energy Division Staff issued a set of recommendations on how to improve the program, including by creating a real-time greenhouse gas emissions factor for energy storage operators to use, and by tying the SGIP incentive payments to greenhouse gas performance. Our comments provide the CPUC with our original analysis on energy storage to support these recommendations, including our recent report, Managing the Future of Energy Storage, and an academic article, by Policy Integrity’s Director, Richard Revesz, and Energy Policy Director, Burcin Unel, Ph.D, on energy storage and greenhouse gas emissions.

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  • Public Comments

    Comments on California’s Proposed State-Specific Vehicle Emissions Regulations

    September 24, 2018

    We recently submitted comments to the California Air Resource Board (CARB) on its proposal to maintain existing statewide vehicle emission regulations. In coming years, the National Highway Traffic Safety Administration and Environmental Protection Agency plan to weaken federal environmental regulations. CARB is aiming to hold California vehicle emissions at current standards to avoid the effects of weakened regulations. Our comments support the feasibility of California’s current standards and encourage CARB to improve its economic impact assessment by accounting for new federal proposals and a broader range of effects.

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  • Public Comments

    Comments on Vermont’s Standard Offer Program

    September 21, 2018

    We recently submitted comments on Vermont’s standard offer program, which is designed to support smaller-scale renewable energy projects. One component of the standard offer program compensates generators that provide benefits to grid operation and management. In the past, the Vermont Public Utilities Commission has focused its view of these benefits to reward only generators that relieve transmission constraints. However, our comments urge the PUC to take a broader view of benefits to grid operation and include resilience benefits and avoiding climate effects on the grid. We cite our July 2018 report, Toward Resilience, to give the PUC more guidance on how to think about and value grid resilience. We also recommend that, when more broadly assessing the entire standard offer program’s benefits, the PUC should monetize any avoided climate externalities by using the social cost of greenhouse gases.

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  • Public Comments

    Comments to Virginia on Integrated Resource Planning

    September 21, 2018

    We recently submitted comments to the Virginia State Corporation Commission on the integrated resource plan (IRP) of the Appalachian Power Company. These comments focus on how the Commission should require utilities to analyze climate impacts when planning how to balance future fossil fuel-based electricity generation against renewable energy options. Under the Virginia Code, the Commission is required to consider whether IRPs are “reasonable” and “in the public interest.” We make the case that climate damages fall squarely within the realm of public interest. Therefore, we argue that the Commission should require electric utilities to more transparently quantify the greenhouse gas emissions of alternatives, and to monetize the associated climate damages using the Social Cost of Greenhouse Gas metrics. Such analysis is necessary to allow the Commission to rationally identify the most efficient plan option that advances social welfare for Virginia, and to allow ratepayers and citizens to better understand the environmental effects of the portfolios chosen.

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  • Court Filings

    Court Vacates Delays of Department of Education’s Borrower Defense Rule

    September 17, 2018

    A United States District Judge recently ruled that the Department of Education’s repeated delays of the Borrower Defense Rule were illegal. We submitted an amicus brief in this case. This 2016 regulation was designed to help students who have been defrauded by for-profit educational institutions discharge their federal student loans. Under Secretary Betsy DeVos, the Department of Education delayed implementation of the Borrower Defense Rule three times, prompting a legal challenge.

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  • News

    Cost of Carbon Website Relaunched

    September 13, 2018

    Costofcarbon.org is now home to our ongoing work on the social cost of carbon (SCC) in U.S. state policy. The domain, which housed SCC-focused research until 2015, has been renovated and refocused to reflect the most important and relevant developments in the application of the SCC in decisionmaking. It includes an easy-to-navigate version of our FAQ Guide for state policymakers, information on state-specific use of the SCC, helpful resources, and more. Our hope is to bring attention to the ways that the SCC continues to be a critical tool used by policymakers in a number of areas, from electricity rate design, to cap-and-trade programs, to fossil fuel royalty rates. A diverse array of stakeholders can benefit from the site’s information and we invite feedback from regulators, partners, and the public on new proceedings that make use of the SCC or matters in which the SCC might be applicable.

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