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Institute for Policy Integrity submitted joint comments with Columbia Law School's Sabin Center for Climate Change Law on the California Public Utilities Commission's Order Instituting Rulemaking to Update Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems. The joint comments emphasize the importance of a comprehensive approach to climate resilience planning across utility sectors.

California has long been a trendsetter in clean energy policy, and our input helped inform the state’s approach for evaluating distributed energy resources (DERs), such as rooftop solar installations. The state’s new approach, which will quantify the environmental benefits of DERs, could help influence other policies around the country, boosting the growth of clean energy sources. Our comments to the California Public Utilities Commission were heavily cited in a March 2018 administrative law judge ruling that was adopted by the Commission, requiring utilities to conduct a societal cost test to determine the cost-effectiveness of DERs. Having been “persuaded by the arguments of the Institute for Policy Integrity,” the ruling will require utilities to calculate the climate benefits of DERs by using the Social Cost of Carbon estimate developed by the Interagency Working Group. As we suggested further, California utilities will also quantify the air quality impacts of DERs. As a result of this decision, California will be able to create incentives encouraging DER installations that have the greatest benefit to the public.

We recently encouraged the California Public Utilities Commission (CPUC) to clarify aspects of its new process for evaluating the social costs and benefits of energy resources. As we discussed in prior comments, the proposed analysis framework, the Societal Cost Test (SCT), will help the Commission to make investments that provide the greatest welfare benefits. Our new comments ask CPUC to provide some additional information in the SCT proposal.

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.

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.

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.

EPA has indicated that it intends to weaken its emission standards for light-duty vehicles and that it may attempt to revoke California’s ability under the Clean Air Act to maintain these protective standards. Our comments to California’s Air Resources Board (CARB) discuss the substantial economic benefits that California would gain from maintaining the more stringent standards that both EPA and California currently require. We submitted our report, Analyzing EPA’s Vehicle-Emissions Decisions, to CARB to provide additional information on why weakening vehicle emission standards set for years 2022-2025 would be economically irrational.

The California Public Utilities Commission (CPUC) is developing a comprehensive policy for integrating Distributed Energy Resource (DERs), like rooftop solar, into its energy system. A March 2018 administrative law judge ruling heavily cited our earlier comments in laying out a revised plan to require the state’s utilities to conduct a societal cost test to help compare the net benefits of different DER technologies. We submitted comments to the CPUC commending the agency for its revisions to the proposed analysis and recommending additional improvements.

California has legislation authorizing its Air Resources Board (ARB) to extend its cap-and-trade program for carbon emissions. This extension, while defining much of the program’s structure, asks ARB to develop some design features through a regulatory process and public feedback. California’s most recent changes to the plan are consistent with our previous comments on the program, and they place California on the path to internalizing the cost of climate change from carbon emissions. Our most recent set of comments encourage ARB to continue to set the price ceiling for carbon permits at least as high as the Social Cost of Carbon set by the Interagency Working Group in 2016, as it does in its Concept Paper on carbon pricing. We also encourage ARB to allocate preferentially any unsold carbon allowances to the price ceiling, rather than to a lower price.

California has long been a trendsetter in clean energy policy, and our input helped inform the state’s approach for evaluating distributed energy resources (DERs), such as rooftop solar installations. The state’s new approach, which will quantify the environmental benefits of DERs, could help influence other policies around the country, boosting the growth of clean energy sources. Our comments to the California Public Utilities Commission were heavily cited in a March 2018 administrative law judge ruling, which, if adopted by the Commission, would require utilities to conduct a societal cost test to determine the cost-effectiveness of DERs.