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Recent Projects

Viewing recent projects in Climate Change and Energy Policy
  • 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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  • Reports

    No Turning Back

    August 27, 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scholars have previously had cause to discuss the circumstances, if any, under which a waiver might permissibly be withdrawn.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.

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  • Public Comments

    Comments to EPA on Weakening the Chemical Disaster Rule

    August 23, 2018

    In May 2018, EPA proposed to repeal significant portions of the Chemical Disaster Rule, a rule that would have improved safety procedures at chemical plants. In response, we submitted comments highlighting the ways in which this proposed deregulatory action is arbitrary and capricious

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  • Public Comments

    Comments to FERC on a Natural Gas Project EIS

    August 13, 2018

    We recently submitted comments to the Federal Energy Regulatory Commission on a natural gas processing and storage facility and marine export terminal in Louisiana, the Calcasieu Pass Project. While the DEIS quantifies the tons of greenhouse gas emissions related to this project—almost 4 million metric tons of carbon dioxide per year from operations, plus hundreds of thousands of tons per year during construction—FERC fails to apply the social cost of greenhouse gas metric to fully account for the climate effects of these emissions. Once again, FERC resorts to flawed arguments used in other inadequate NEPA reviews to implicitly justify why the Commission chose not to use the social cost of greenhouse gases metric for the Calcasieu project. Our comments provide a detailed rejection of FERC’s arbitrary and misleading rationale for failing to use the social cost of greenhouse gases, and offer additional guidance on how to monetize climate effects consistent with the currently best available science and economics.

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  • News

    Policy Integrity Article Cited in Suit Against Interior’s Royalty Policy Committee

    August 9, 2018

    A group of NGOS, led by the Western Organization of Resource Councils, recently filed a complaint in the District of Montana Court regarding Secretary of the Interior Zinke’s Royalty Policy Committee (RPC). The complaint argues that though the RPC should be acting transparently on behalf of American taxpayers, it is in fact working in secret to advance the interest of extractive industries. In the complaint, the petitioners cite a recent Harvard Environmental Law Review article by Policy Director, Jayni Foley Hein, Federal Lands and Fossil Fuels: Maximizing Social Welfare in Federal Energy Leasing, to help make their case.

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  • Academic Articles/Working Papers

    The Future of Distributed Generation

    August 8, 2018

    As distributed energy generation is becoming increasingly common, the debate on how a utility’s customers should be compensated for the excess energy they sell back to the grid is intensifying. And net metering, the practice of compensating for such energy at the retail rate for electricity, is becoming the subject of intense political disagreement. Utilities argue that net metering fails to compensate them for grid construction and distribution costs and that it gives rise to regressive cost shifting among its customers. Conversely, solar energy proponents argue that the compensation should be higher than the retail rate to account for other benefits that distributed generation systems provide, such as the resulting climate change and other environmental benefits, as well as the savings resulting from not needing to build new installations to provide additional capacity. This ongoing debate is leading to significant changes to net metering policies in many states.

    This article provides an overview of the benefits and the costs of distributed generation and highlights the analytical flaws and missing elements in the competing positions and in most existing policies. We propose an alternative approach that recognizes the contributions to the electric grid of both utilities and distributed generators. The article is excerpted and revised from a longer academic article, Managing the Future of the Electricity Grid: Distributed Generation and Net Metering, which was selected by Environmental Law Reporter as one of the five best environmental law articles published in the 2016-2017 academic year.

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  • Public Comments

    Comments to Interior on Offshore Oil Well Control Revisions

    August 6, 2018

    After the Deepwater Horizon explosion and oil spill, the Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) issued regulations designed to improve the safety of offshore drilling operations. Finalized in 2016 after six years of extensive public involvement, these safeguards are now in the process of being rolled back by BSEE. Our comments to BSEE argue that it should not move forward with its notice of intent to repeal and/or modify the Blowout Preventer Systems and Well Control Rule, because BSEE has not provided a reasoned explanation for weakening and repealing safety requirements that it found necessary in 2016. BSEE must analyze all of the forgone societal benefits from rolling back the finalized safeguards, including safety and environmental risk reduction, time savings, industry cost savings, reduced fatalities, and lower externality costs.

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  • Court Filings

    Positive Ruling in Case on BLM Climate Impacts Leasing

    August 3, 2018

    A District of Montana judge recently ordered that the Bureau of Land Management (BLM) must update two resource management plans (RMPs) for the Powder River Basin in order to better assess the plans’ climate impacts. Dr. Peter Howard, our Economics Director, submitted an expert declaration in the case in May on the environmental, public health, and social welfare costs of the RMPs, focusing on the social cost of greenhouse gases metric. The suit was brought by the Western Organization of Resource Councils, with other NGOs, against BLM for failing to conduct a sufficient analysis of the climate effects of possible fossil fuel leasing, in violation of the National Environmental Policy Act. Because almost half of the country’s coal is mined in the Powder River Basin, there are significant greenhouse gas emissions implications for mineral leasing in the area.

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  • Reports

    Toward Resilience

    August 1, 2018

    Grid resilience—generally, the electric grid’s ability to resist/absorb, manage, quickly respond, and recover from/adapt to high-impact, low-probability external shocks—has been a concern for electric utilities and energy planners for decades. While recent extreme weather and cyber security concerns have prompted the federal government to pursue policies that support coal and nuclear power plants, a more systematic focus on resilience will lead to very different solutions than what has been proposed by the Department of Energy.

    Our report aims to assist policymakers in understanding grid resilience and evaluating potential interventions aimed at improving grid resilience. It develops a definition of resilience grounded in academic literature; describes a methodology for calculating the costs and benefits of potential grid resilience improvements; identifies legal authorities that states and federal agencies can use to implement resilience-enhancing policies and investments; and analyzes the Trump Administration’s proposals to support coal and nuclear plants in light of the insights developed in the report.

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  • Public Comments

    Comments to the Nevada PUC on the Proposed Regulation to Implement SB 65

    July 25, 2018

    The Nevada Public Utilities Commission recently released a proposed regulation to implement Senate Bill 65, which directs the PUC to give preference to those measures and sources of supply that provide the greatest economic and environmental benefit to the State. In our joint comments with Western Resource Advocates and Environmental Defense Fund, we express our support for these revisions to Nevada’s resource planning regulations. Specifically, we support the Commission’s application of the Interagency Working Group (IWG) Social Cost of Carbon (SCC) estimates to calculate the Present Worth of Societal Costs in Nevada, as reflected in the proposed regulation. In addition, we update the PUC on the use of the IWG SCC estimates in other states, including California, Colorado, Minnesota, New York and Washington State.

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