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Comments to Virginia on Developing an Energy Storage Rule
The Virginia State Corporation Commission asked for input in advance of developing a rule for energy storage deployment. Our comments note that energy storage deployment can increase emissions from the electricity sector, even if those deployments also facilitate the integration of variable renewable resources. We urge the Commission, under the Virginia Clean Economy Act, to adopt a rule ensuring that energy storage resources are deployed and operated in ways that reduce net emissions.
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Weakening Our Defenses
How the Trump Administration’s Deregulatory Push Has Exacerbated the Covid-19 Pandemic
The failure of the federal government to adequately safeguard the health, environment, and economy of the United States with efficient regulatory protections is not a new phenomenon. For over three years now, the Trump administration has systematically delayed, undermined, and erased key regulations that protect our health, our environment, our workplaces, our living conditions, and our economy. The steady erosion of regulatory safeguards has severely compromised our baseline defenses against Covid-19.
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Wisdom of the Experts
Using Survey Responses to Address Positive and Normative Uncertainties in Climate-Economic Models
The social cost of carbon (SCC) and the climate-economic models underlying this prominent US climate policy instrument are heavily affected by modeler opinion and therefore may not reflect the views of most climate economists. To test whether differences exist, we recalibrate key uncertain model parameters using formal expert elicitation: a multi-question online survey of individuals who have published scholarship on the economics of climate change. Read the article, published in Climatic Change.
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Comments to DOE on Energy Conservation Standards for Water Heaters
Public Comments / July 6, 2020 / DownloadThe Department of Energy (DOE) asked for input on conducting its national impact analysis, including on market failures, its emissions analysis, and monetization of benefits of emissions reductions. We submitted comments suggesting that DOE continue to monetize the full climate benefits of emissions reductions using the best available estimates of the social cost of greenhouse gases.
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Comments to DOE on Energy Conservation Standards for External Power Supplies
Public Comments / July 6, 2020 / DownloadThe Department of Energy (DOE) asked for input on conducting its national impact analysis, including on market failures, its emissions analysis, and monetization of benefits of emissions reductions. We submitted comments suggesting that DOE continue to monetize the full climate benefits of emissions reductions using the best available estimates of the social cost of greenhouse gases.
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Amicus Brief on EPA’s Revocation of the California Auto Emissions Waiver
Court Filings / July 6, 2020 / DownloadWe filed a brief in the D.C. Circuit supporting a challenge to the Environmental Protection Agency’s (EPA) decision to revoke the waiver of preemption that allowed California (and more than a dozen states following California's standards) to set critical auto emission standards to further restrict greenhouse gases and other harmful air pollutants. EPA wrongfully concluded that it has virtually unconstrained authority to revoke a preemption waiver under Section 209(b) of the Clean Air Act. We explain how the agency overlooks key countervailing principles and misconstrues the purpose and mechanics of the waiver provision.
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Comments to FERC on Transmission Incentives
Public Comments / July 1, 2020 / DownloadThe Federal Energy Regulatory Commission proposed changes to its electric transmission incentives, which aim to spur the deployment of technologies that enhance reliability, efficiency, and capacity of transmission facilities. We submitted comments identifying significant problems with the proposal, including its reliance on a benefit-cost ratio for project selection.
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Energy Transition, Distributed Energy Resources, and the Need for Information
Modernizing the U.S. power grid to advance the clean energy transition, to increase the deployment of new technologies such as smart and controllable appliances, electric vehicles, and energy storage, and to reduce emissions is the mainstream discussion in today’s utility regulation. Policymakers around the country are implementing various types of reforms ranging from technology mandates to new tariffs aimed at unlocking competitive forces to achieve their policy goals. We briefly overview the potential information problems that can arise, discuss the importance of information in energy policy design for DER deployment, and then conclude by suggesting directions for future policy research.
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Comments to DOE on Energy Conservation Standards for Motors
June 22, 2020 / DownloadThe Department of Energy requested input on impact and emissions analysis for upcoming energy conservation standards. We submitted comments encouraging DOE to continue to monetize the full climate benefits of greenhouse gas emissions reductions.
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Comments to FERC on Middlesex Extension Natural Gas Project
Public Comments / June 22, 2020 / DownloadWe submitted comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Middlesex Extension Project in New Jersey. FERC failed to provide a meaningful analysis of the pipeline facilities' climate effects.
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