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Comments to DOE on Clean Hydrogen Production Standard
The Department of Energy (DOE) solicited comments on its draft guidance for the Clean Hydrogen Production Standard, a target that will be selected by DOE for the carbon intensity of clean hydrogen. This standard relates to DOE’s implementation of the hydrogen-hub provision of the Bipartisan Infrastructure Law. Policy Integrity and WattTime submitted comments to DOE on how to accurately measure the carbon emissions from using grid electricity to produce hydrogen. In particular, we suggested the use of a marginal-emissions approach instead of an annual-average approach. We also recommended that DOE adhere to rigorous carbon-accounting principles if hydrogen producers want to use market instruments like renewable energy credits or power-purchase agreements to characterize the carbon intensity of hydrogen produced using grid electricity.
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Supplemental Comments Addressing Impact of West Virginia v. EPA on FERC’s Proposed Policy Statements for Natural Gas Infrastructure
In February, the Federal Energy Regulatory Commission proposed two policy statements that called for the consideration of climate impacts in pipeline certificate proceedings. In April, we filed two comments letters on these proposed policy statements, including one letter filed jointly with over two dozen legal scholars rebutting arguments that the Commission lacks authority to consider climate effects in its oversight of natural gas infrastructure under the Natural Gas Act and, relatedly, that the proposed policy statements implicate the major questions doctrine. Today, we submitted supplemental comments rebutting arguments that the Supreme Court’s recent decision on the major questions doctrine in West Virginia v. EPA somehow affects the Commission’s ability to finalize its proposed policy statements.
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Comments to Bureau of Ocean Energy Management on Proposed Five-Year Offshore Leasing Plan
In July, the Bureau of Ocean Energy Management (BOEM) released its proposed five-year offshore leasing plan, which contemplates scheduling anywhere from zero to eleven lease sales over the coming half-decade. As part of that proposal, BOEM conducts a cost-benefit analysis in which it finds net benefits from offshore leasing, but recognizes uncertainty and specifically calls for comment on this analysis.
In response to this call for comments, Policy Integrity submitted two original reports offering extensive feedback on BOEM’s cost-benefit analysis. As detailed in those reports, BOEM’s analysis severely understates the costs of OCS leasing—particularly the climate costs. Our reports offer original analysis and modeling finding that, properly considered, the climate costs of offshore leasing alone may exceed the total benefits from that leasing.
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Comments to Connecticut on Energy Storage and Emissions
The Connecticut Public Utilities Regulatory Authority (PURA) issued a straw program design for electric storage. We submitted comments that support PURA's efforts to make energy storage part of its overarching decarbonization agenda and provide feedback. It is important, as we explain, that PURA take into account the potential emissions consequences of energy storage operations in designing its performance-based incentive.
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The Public Interest Review for LNG-Related Authorizations
After a meteoric rise in production over the past decade, the United States has become the largest exporter of liquefied natural gas (LNG) in the world. Yet, the analysis behind LNG terminal and export approvals overlooks climate and environmental justice impacts, despite promises of imminent reform. Policy Integrity’s new report provides a comprehensive look at the Department of Energy’s (DOE) and the Federal Energy Regulatory Commission’s (FERC) past practice in this space and offers recommendations for improving their review of the climate and environmental justice impacts of LNG approvals.
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The Social Cost of Greenhouse Gases: A Guide for State Officials
As states step up on climate action, they need a way to weigh climate goals against other policy objectives. The social cost of greenhouse gases (SC-GHG) can help policymakers understand the costs and benefits of climate action and inaction. This new guide for state officials explains why the SC-GHG is a useful policy tool and how it can be applied.
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Comments to DOE on Supplemental Environmental Analysis for Alaska LNG Project
After the Department of Energy published a supplemental environmental impact statement claiming that exporting liquefied natural gas from a proposed Alaska terminal would decrease greenhouse gas emissions, we submitted comments challenging the Department’s methodology and assumptions. In particular, our comment letter explains that the Department’s analysis unreasonably assumes that the Project would merely displace existing exports from Gulf Coast facilities, and thus overlooks the inevitable economic reality that the Project will increase total natural gas supply and consumption. As our comment letter explains, courts have rejected this “perfect substitution” assumption in related contexts. Moreover, our letter explains that the Department’s lifecycle analysis insufficiently considers the choice of destination countries and is inconsistent with the agency’s analysis of economic impacts.
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Amicus Brief in Support of Upholding PJM’s Focused Minimum Offer Price Rule
Last July, PJM Interconnection (the electricity grid operator for 13 states and the District of Columbia) submitted revisions to its Minimum Offer Price Rule (MOPR) for its capacity market to the Federal Energy Regulatory Commission (FERC) for approval. The new rule (the “Focused MOPR”) would remove an artificial barrier to market entry for resources that receive such externality payments under state climate and clean energy policies. Policy Integrity filed an amicus brief in support of FERC and PJM’s Focused MOPR explaining why the rule is welfare-enhancing and would not threaten reliability.
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Comments on the New York Climate Action Council’s Draft Scoping Plan
The Climate Leadership and Community Protection Act (CLCPA or the Act) committed New York to an ambitious set of changes across all sectors of the economy. The development of a Scoping Plan, as called for by the Act, will help steer New York's agencies--and legislature--as they initiate those changes. Policy Integrity's comments focus on the Electricity and Gas System Transition chapters of the Draft Scoping Plan. In addition to voicing support for several of the measures listed in that plan, those comments encourage adoption of further measures in a final version of the plan. Those additional measures would support greater coordination of electricity sector stakeholders' decisions and would create a greater degree of certainty about the nature and pace of gas system transition.
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Joint Comments to SEC on its Proposal to Enhance and Standardize Climate-Related Disclosures
Together with the Environmental Defense Fund and Professor Madison Condon of Boston University School of Law, we submitted three sets of comments to the Securities and Exchange Commission (SEC) in support of its Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (Proposed Rule). The Proposed Rule would require publicly traded companies to disclose important information about the extent to which climate change is already affecting their financial performance, their approach to climate-related risk management, their climate-relevant governance structures, and their greenhouse gas emissions, which serve as a proxy for exposure to risk from policy- and market-driven shifts to a clean-energy economy.
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