Recent Projects

Peter Howard and Jason Schwartz provided an expert report on Colorado’s Zero Emission Vehicle program, which will reduce millions of tons of greenhouse gas emissions annually. They demonstrate how the program’s climate benefits can be monetized and how those estimates can provide useful context for decisionmakers and the public.

We submitted joint comments to the Federal Energy Regulatory Commission (FERC) on its environmental assessment of the Jordan Cove natural gas exports project in Oregon. FERC failed to provide a meaningful analysis of the pipeline’s climate effects.

We submitted joint comments on the Army Corps of Engineers’ environmental assessment of the Pebble Mine Project in southwest Alaska. The Corps quantifies greenhouse gas emissions from the project but fails to provide a monetized estimate of the climate damages those emissions will produce.

The Office of Surface Mining and Reclamation Enforcement (OSM) issued its environmental assessment of extending the Caballo Mine West Tract federal coal lease. The mining plan would extend the life of the mine by approximately nine years, from 2042-2051, and increase the amount of coal mined from an average of 10.1 million tons per year to approximately 13.5 tons per year. Despite quantifying over 23 million tons of yearly carbon dioxide equivalent emissions, OSM does not include a monetized estimate of the climate damages those emissions will produce. We submitted joint comments asking that OSM use the social cost of greenhouse gases to better weigh the real-world impacts of potential coal leasing.

As part of EPA’s June 5-6 meeting of the Chartered Science Advisory Board (SAB), we submitted both oral and written input on several issues, including the Clean Water Rule, power-sector emissions of air toxics, vehicle emissions standards, and the Science Transparency Rule.

The Iowa Utilities Board is currently reviewing its policies on energy efficiency planning. We submitted comments supporting some of the suggestions made by stakeholders to better gauge the benefits of the energy efficiency programs.

The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) are proposing to weaken key fuel economy and greenhouse gas emissions standards for future vehicle models. In October, we highlighted our concerns with some of the economic analysis supporting the proposal. The Alliance of Automobile Manufacturers submitted comments that included economic analysis supporting the proposed rule prepared by NERA Economic Consulting and Trinity Consultants. In December, we wrote supplemental comments rebutting NERA and Trinity’s analysis, identifying serious flaws and unexplained departures from longstanding practices. NERA recently responded.

Our latest comments detail how NERA’s response does not address many of the problems we previously discussed. As our comments explain, the analysis relies on unreliable modeling and methodologies, for which NERA still has not provided critical details. NERA also misstates or fails to respond to our points on a number of topics, such as scrappage and fuel savings benefits. We point out the shortcomings in NERA’s response and provide more detail on each of the topics.

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.

The Department of Energy called for input on developing and analyzing energy conservation standards for small electric motors. We submitted comments encouraging DOE to account for the monetized climate benefits of greenhouse gas emissions using social cost of carbon estimates.