Recent Projects

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 expert testimony on the benefits of Colorado’s proposed Low Emission Vehicle Program. The LEV program could avoid millions of tons of greenhouse gas emissions, and we explain to the Colorado Air Quality Control Commission the importance of and methodology for monetizing the real-world contributions of those emissions to global climate change. Our report shows, by applying Social Cost of Carbon estimates, that Colorado’s proposed LEV program could generate billions of dollars’ worth of climate benefits.

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.

We recently submitted comments on Vermont’s standard offer program, which is designed to support smaller-scale renewable energy projects. One component of the standard offer program compensates generators that provide benefits to grid operation and management. In the past, the Vermont Public Utilities Commission has focused its view of these benefits to reward only generators that relieve transmission constraints. However, our comments urge the PUC to take a broader view of benefits to grid operation and include resilience benefits and avoiding climate effects on the grid. We cite our July 2018 report, Toward Resilience, to give the PUC more guidance on how to think about and value grid resilience. We also recommend that, when more broadly assessing the entire standard offer program’s benefits, the PUC should monetize any avoided climate externalities by using the social cost of greenhouse gases.

We recently submitted comments to the Virginia State Corporation Commission on the integrated resource plan (IRP) of the Appalachian Power Company. These comments focus on how the Commission should require utilities to analyze climate impacts when planning how to balance future fossil fuel-based electricity generation against renewable energy options. Under the Virginia Code, the Commission is required to consider whether IRPs are “reasonable” and “in the public interest.” We make the case that climate damages fall squarely within the realm of public interest. Therefore, we argue that the Commission should require electric utilities to more transparently quantify the greenhouse gas emissions of alternatives, and to monetize the associated climate damages using the Social Cost of Greenhouse Gas metrics. Such analysis is necessary to allow the Commission to rationally identify the most efficient plan option that advances social welfare for Virginia, and to allow ratepayers and citizens to better understand the environmental effects of the portfolios chosen.

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.

We recently submitted comments about to the Colorado Public Utilities Commission, which is reviewing its rules on electric resource planning (“ERP”). Our comments aim is to ensure that a proper valuation of externalities is integrated into Colorado’s ERP process, and we suggest using the Social Cost of Carbon to monetize greenhouse gas externalities.

Input from the Institute for Policy Integrity helped encourage Nevada to modernize its energy policymaking by accounting for the impacts of carbon pollution in key electric utility planning decisions. At the recommendation of Policy Integrity and partner groups, the Public Utilities Commission of Nevada recently included language on the Obama-era Interagency Work Group’s Social Cost of Carbon (SCC) in new rules governing utilities’ resource plans.Utilities will now have to analyze and clearly disclose the damages caused by climate change when evaluating alternative long-term resource plans. This information will be used by utilities and the Commission when selecting their preferred resource plan.