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Comments on Proposed Offshore Leasing Program for 2017-2022
We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values.
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Legal Pathways to Reducing Greenhouse Gas Emissions Under Section 115 of the Clean Air Act
The most efficient legal tool for addressing U.S. climate pollution can likely be found in an unused provision of the Clean Air Act. Section 115 of the Act, titled “International Air Pollution,” authorizes the EPA to develop and implement an economy-wide, market-based program to reduce domestic greenhouse gas emissions. This article, jointly authored by a team of law professors and attorneys at three of the country’s leading institutes focused on climate change and environmental law, offers an in-depth analysis of Section 115, which would provide the most flexible approach for achieving the targets from the Paris climate agreement.
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The Bureau of Land Management’s Modeling Choice for the Federal Coal Programmatic Review
There are multiple power sector models available to the Department of Interior (DOI)’s Bureau of Land Management (BLM) for analyzing the effect of current and alternative coal regulations and leasing policies during preparation of its programmatic environmental impact statement (PEIS). This document lays out model selection criteria to assist BLM in weighing the benefits and costs of these available models, and offers recommendations for model selection, highlighting the tradeoff between model complexity and transparency.
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Revesz Testifies at Senate Hearing on Clean Power Plan
On June 9, Richard Revesz testified at a Senate Environment and Public Works Committee hearing focused on the Supreme Court’s stay of the Clean Power Plan.
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National Academy of Sciences Reviews Social Cost of Carbon
The National Academy of Sciences (NAS) is currently conducting a review of the methodologies used to calculate the Social Cost of Carbon (SCC). We submitted comments to NAS to help inform this process.
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Distributed Energy Compensation Comments for NARUC
As distributed energy resources (“DER”) are becoming increasingly common, the debate on how customers with such systems should be compensated is intensifying in many states. The National Association of Regulatory Utility Commissioners (NARUC) is creating a Distributed Energy Resources Compensation Manual to assist states with these policy decisions. We recently submitted comments to NARUC’s Staff Subcommittee on Rate Design regarding the most economically desirable approach to use for DER compensation.
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Understanding the Stay
Implications of the Supreme Court’s Stay of the Clean Power Plan
Since the Supreme Court stayed EPA’s Clean Power Plan, which regulates carbon dioxide emissions from existing fossil fuel-fired power plants, opponents of the plan have been making unfounded assertions about the consequences of the stay. This policy brief aims to clarify the stay’s implications for EPA’s implementation work and the plan’s future compliance deadlines.
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New York Clean Energy Standard - White Paper Comments
The 2015 New York State Energy Plan set one of the most ambitious clean energy targets in the nation: 50 percent of all electricity used in the state should be generated by renewable energy sources. The Department of Public Service Staff recently released a White Paper on the Clean Energy Standard, with recommendations on how to achieve this ambitious goal. We submitted comments to the New York State Public Service Commission, outlining some additional steps that can help ensure that the Clean Energy Standard is not excessively costly, and is effective in achieving all of its policy goals.
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Comments on Net Metering and Distributed Energy Valuation in New York
We recently submitted comments to the New York Public Service Commission on how the Commission should develop an interim successor to its net metering policy, and how distributed energy resources should be valued in the future. We filed the comments jointly with the Environmental Defense Fund. To begin to move the retail electricity markets toward efficient and accurate recognition of the value of distributed energy resources, we suggest that the Commission should enhance its existing net energy metering policy to align compensation with the system benefits provided by distributed energy resources; establish a fully unbundled retail price structure; and specifically account for the environmental benefits of distributed energy resources in future pricing structures.
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Balancing on the Grid Edge
Regulating for Economic Efficiency in the Wake of FERC v. EPSA
This new article from senior attorney Denise Grab is featured in a special edition of the Harvard Environmental Law Journal that focuses on the Supreme Court’s FERC v. EPSA case.
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