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Academic Articles/Working Papers
(Not So) Clean Peak Energy Standards
Growth in electricity storage has the potential to increase emissions from power generation. Concerns about this outcome are currently prompting many policies to address the issue. We study a particularly popular policy proposal called the “Clean Peak Standard” that incentivizes storage to discharge during periods of high electricity demand. The stated goal of the policy is to shift storage discharge to offset production from generators with high pollution emissions. We show that the policy is largely ineffective at achieving this emissions reduction goal. The policy reinforces existing incentives faced by storage operators, so it does not have a strong effect on discharging behavior. It is also unable to capture high-frequency changes in marginal operating emissions rates. Alternative policies, such as a carbon tax, are more effective at reducing the emissions increase caused by storage. Policymakers considering Clean Peak-style policies should instead consider these alternative policies.
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Public Comments
Comments to the Department of Labor on Tip Pooling
The Wage and Hour Division of the Department of Labor (DOL) is proposing to implement new tip regulations under the Fair Labor Standards Act. We submitted comments asking DOL to provide a more detailed explanation of the proposed rule and improve its underlying analysis.
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Reports
Getting the Value of Distributed Energy Resources Right
Our report notes the growing presence of distributed energy resources, like solar panels and energy storage installations, and explains how they should be compensated for providing electricity services valued by utilities and their customers. Currently, 40 states use net energy metering programs to compensate DERs. We describe a promising alternative, “value stacking,” which better reflects DERs’ value, and provide suggestions for how to implement this approach.
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Public Comments
Comments to EPA on Methane Emissions from Oil and Gas Operations
The Environmental Protection Agency (EPA) proposed revisions to New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector. We submitted comments focusing on EPA’s flawed and legal economic justifications for the rule.
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New Resource on Climate Damages of U.S. LNG Exports
The Institute for Policy Integrity has launched a new resource that compiles the greenhouse gas emissions and resulting damages from liquefied natural gas (LNG) export terminals.
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Public Comments
Comments to the State Department on the Proposed Keystone XL Pipeline
We submitted comments on the U.S. Department of State’s supplemental environmental impact statement for the proposed Keystone XL Pipeline project. A federal district court ruled that the agency’s original impact analysis was inadequate, failing to take all relevant information into account when projecting that the pipeline would not affect total crude oil production. The Department’s new analysis projects that the pipeline will likely increase total crude oil production by only partially offsetting production that would have occurred elsewhere under a “no action” scenario, but irrationally fails to account for this substitution effect when projecting the pipeline’s economic benefits. Our comments argue that the Department continues to violate NEPA by its lopsided treatment of the pipeline’s costs and benefits, through not only its inconsistent treatment of substitution effects but also its failure to assess the pipeline’s climate-related impacts through monetization.
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Public Comments
Comments to EPA on Water Quality Trading Proposals
The Environmental Protection Agency (EPA) requested input on policy approaches to promote market-based programs that will improve water quality. We submitted comments suggesting that EPA provides additional clarity, works to avoid undermining key permitting goals, and considers using alternate market-based structures before reissuing its proposals.
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Public Comments
Comments to Colorado on Participation in Centralized Electricity Markets
The Colorado Public Utilities Commission is evaluating different options for electric utility participation in centralized electricity markets, as part of the Colorado Transmission Coordination Act. We submitted comments encouraging the Commission to move the state to a centralized market, which would help accomplish energy goals and would benefit generators, utilities, and customers.
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Public Comments
Comments to the New York Public Service Commission on Resource Adequacy
We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.
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News
Courts Strike Down Conscience Protections Rule
Three federal courts—in the Southern District of the New York, the Northern District of California, and the Eastern District of Washington—vacated the Department of Health and Human Services’ conscience protections rule, which would have reduced healthcare access for women and LGBT individuals. In amicus briefs, Policy Integrity had criticized HHS for, among other things, failing to consider the rule’s likely health costs. The SDNY decision was consistent with our argument that HHS failed to provide a reasoned explanation for the rule.
