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Recent Projects

  • Academic Articles/Working Papers

    Will You Be There for Me the Whole Time?

    February 7, 2019

    This paper discusses how variations in the availability of various resources (generation seasonality) and the fluctuations in the electricity usage (load seasonality) relate to efficient capacity market design. Even though capacity markets have been around for two decades, the necessity as well as the design of these markets are subjects of ongoing debates. Many design questions, such as how to determine the amount of capacity to be procured, how to prevent market power, or how to provide incentives for performance dominate both the academic literature and the policymaking discussions. Another design aspect that plays a crucial role for market participants is the length of the capacity product procured (“obligation period”), because it defines the length of time for which a seller commits to maintaining its capacity available. However, a thorough analysis of obligation periods has been overlooked by literature and policymaking discussions. Our article works to provide this analysis.

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  • Public Comments

    Comments to FERC on NYISO and Energy Storage Resources

    February 7, 2019

    A new wholesale energy market policy proposal in New York could undermine market efficiency by limiting the compensation available for energy storage resources. The New York Independent System Operator (NYISO) recently submitted changes to its market rules to encourage energy storage, as required by an order from the Federal Energy Regulatory Commission (Order No. 841). The filing prevents energy storage resources from participating in the wholesale markets if they also participate in retail compensation programs. We submitted comments explaining how this participation barrier is inconsistent with FERC’s requirements and should be changed.

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  • Public Comments

    Comments to FERC on Adelphia Gateway Pipeline Project

    February 4, 2019

    The Federal Energy Regulatory Commission (FERC) recently released an Environmental Assessment (EA) for the Adelphia Gateway Project. FERC quantifies nearly 90,000 tons per year of direct carbon dioxide-equivalent emissions, but offers no meaningful analysis of the pipeline’s climate impacts. We submitted joint comments urging FERC to better weigh the significance of project’s impacts using the social cost of greenhouse gases methodology.

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  • Public Comments

    Comments to FERC on Annova Natural Gas Project

    February 4, 2019

    In the Federal Energy Regulatory Commission’s (FERC) Environmental Impact Statement (EIS) for the Annova LNG Brownsville Project, the agency quantifies over 350,000 tons per year of direct operational carbon dioxide-equivalent emissions from the proposed natural gas terminal. But FERC fails to provide meaningful analysis of the resulting climate impacts. We submitted joint comments urging FERC to better contextualize the project’s impacts using the social cost of greenhouse gases methodology.

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  • Issue Briefs

    A Lower Bound

    January 31, 2019

    The Social Cost of Carbon, developed by the Obama-era Interagency Working Group (IWG), is the best available tool for measuring the economic damages from greenhouse gas emissions. It has been used in analysis for over 100 federal regulations that affect greenhouse gas emissions, as well as by a number of states in electricity and climate policy. Still, many significant impacts identified by the Intergovernmental Panel on Climate Change are difficult to quantify and so have been omitted from the IWG SCC estimates. Impacts such as increased fire risk, slower economic growth, and large-scale migration are all unaccounted for, despite their potential to cause large economic losses. Our new issue brief discusses these omissions and other variables that will influence climate outcomes. We encourage policymakers to account for this likely underestimate by viewing the SCC as a lower bound for damages.

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  • Academic Articles/Working Papers

    Congress and the Executive

    January 30, 2019

    Critics of the administrative state have been urging Congress to rein in regulatory action, claiming that regulations created by executive agencies are undesirable as a matter of policy and are in violation of constitutional principles. In a troubling development, the Trump Administration has also turned away from cost-benefit analysis in order to carry out its anti-regulatory agenda, disregarding an established bipartisan consensus that stretched back several decades. This article, published in the Michigan State Law Review, argues that this anti-regulatory position is unwarranted. These executive regulatory actions produced large net benefits to the American people, were carried out pursuant to authority delegated by Congress, and were reviewed by the courts. By contrast, more robust action by Congress, as long as Congress continues to exhibit its current gridlock on important policy issues like climate change, is unlikely to be beneficial.

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  • Public Comments

    Comments to EPA on Delay of Emissions Rule for Wood Heaters

    January 14, 2019

    The Environmental Protection Agency (EPA) is proposing to amend the 2015 New Source Performance Standards (NSPS) for residential wood heating devices. This change would allow retailers to sell non-compliant wood heaters for two years past the original 2020 compliance date. We submitted comments explaining that the proposed rule imposes net costs on society and is not justified by EPA’s faulty analysis.

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  • Public Comments

    Comments to EPA on Delay of Landfill Emission Guidelines

    January 3, 2019

    In 2016, EPA finalized Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills. Once implemented, the regulation will deliver significant net benefits from reducing pollution that contributes to climate change and other harmful impacts to human health. EPA, however, is proposing to substantially delay the implementation of these protections. We submitted comments that point out how EPA fails to justify the proposed delay and assess its social costs.

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  • Court Filings

    Amicus Brief on Climate Impacts of the PennEast Pipeline Project

    December 28, 2018

    In January, the Federal Energy Regulatory Commission (FERC) authorized the construction and operation of the PennEast Pipeline Project, a 116-mile natural gas pipeline between Pennsylvania and New Jersey and associated facilities. FERC’s Environmental Impact Statement (EIS) showed that the project will result in an increase in greenhouse gas emissions but did little more than quantify those emissions, failing to fully analyze and consider the climate impacts of the project. We submitted an amicus brief to the U.S. Court of Appeals for the District of Columbia Circuit that demonstrates how FERC could have used the Social Cost of Carbon to analyze the pipeline’s climate impacts.

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  • Public Comments

    Comments to BLM on Resource Management in the Powder River Basin

    December 21, 2018

    The Bureau of Land Management (BLM) is considering amending Resource Management Plans for the Miles City and Buffalo field offices in the Powder River Basin. The agency will prepare an environmental impact statement (EIS) for the proposal. We submitted comments at the scoping phase urging BLM to provide analysis that quantifies the external costs of fossil fuel development in the region and evaluates critical land management alternatives.

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