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Recent Projects

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  • Comments on California Public Utilities Commission’s New Analysis Framework

    April 15, 2019

    We recently encouraged the California Public Utilities Commission (CPUC) to clarify aspects of its new process for evaluating the social costs and benefits of energy resources. As we discussed in prior comments, the proposed analysis framework, the Societal Cost Test (SCT), will help the Commission to make investments that provide the greatest welfare benefits. Our new comments ask CPUC to provide some additional information in the SCT proposal.

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  • Public Comments

    Comments to DOE on Energy Conservation Standards for Direct Heating Equipment

    April 12, 2019

    The Department of Energy (DOE) recently issued a request for information on the energy conservation standards for direct heating equipment. We submitted comments that advise the Department to monetize climate benefits from greenhouse gas emissions reductions and discuss market-based approaches to energy conservation standards.

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  • Reports

    Opportunities for Valuing Climate Impacts in U.S. State Electricity Policy

    April 2, 2019

    With an absence of federal leadership on climate change, many states have worked to reduce greenhouse gas emissions on their own, often by incorporating a broader range of considerations into electricity policy. Our report assesses the potential to expand the valuation of climate damages in state electricity policy using Social Cost of Carbon metrics. We examine existing statutes and regulations in all 50 states to identify opportunities for valuing climate impacts around the country.

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  • Public Comments

    Comments to the Colorado Public Utilities Commission on Electricity Rule Changes

    March 29, 2019

    The Colorado Public Utilities Commission is amending its rules relating to utilities, electric resource planning, and renewable energy standards. We submitted comments explaining why the Commission should use Social Cost of Greenhouse Gases estimates to monetize the externalities of carbon pollution. Our recommendations include rule revisions and new language that will help include monetized estimates of climate impacts in all relevant decisionmaking.

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  • News

    Colorado Senate Testimony on the Social Cost of Carbon

    March 19, 2019

    Colorado is considering a major overhaul of its electric resource planning rules and renewable energy standards. Jason Schwartz recently provided testimony in a Senate hearing on the reauthorization of the state’s Public Utilities Commission as part of this overhaul. Schwartz spoke about a possible requirement for the PUC to weigh the social costs of pollution in its decisions. Coloradoans, he explained, are paying the costs of climate pollution in the form of more dangerous wildfires, agricultural damages, declining snowpack, and a range of severe health effects. Many of these important costs can be quantified. In his testimony, Schwartz recommended that the PUC uses Social Cost of Greenhouse Gases metrics when evaluating energy resources in order to improve public welfare.

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  • Academic Articles/Working Papers

    Markets, Externalities, and the Federal Power Act

    February 22, 2019

    This article, published in the New York University Environmental Law Journal, shows how the Federal Energy Regulatory Commission (FERC) must attempt to address the external cost of carbon dioxide (CO2) emissions to achieve an efficient electricity market. CO2 emissions impose a significant cost on society by contributing to climate change. The electricity sector is a major source of these emissions, yet their external cost is not fully reflected in electricity rates, and the market outcomes thus do not adjust to reflect those true costs—a classic market failure. This leads to emissions that are higher than optimal.

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  • Academic Articles/Working Papers

    Will You Be There for Me the Whole Time?

    February 7, 2019

    This paper discusses how variations in the availability of various resources (generation seasonality) and the fluctuations in the electricity usage (load seasonality) relate to efficient capacity market design. Even though capacity markets have been around for two decades, the necessity as well as the design of these markets are subjects of ongoing debates. Many design questions, such as how to determine the amount of capacity to be procured, how to prevent market power, or how to provide incentives for performance dominate both the academic literature and the policymaking discussions. Another design aspect that plays a crucial role for market participants is the length of the capacity product procured (“obligation period”), because it defines the length of time for which a seller commits to maintaining its capacity available. However, a thorough analysis of obligation periods has been overlooked by literature and policymaking discussions. Our article works to provide this analysis.

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  • Public Comments

    Comments to FERC on NYISO and Energy Storage Resources

    February 7, 2019

    A new wholesale energy market policy proposal in New York could undermine market efficiency by limiting the compensation available for energy storage resources. The New York Independent System Operator (NYISO) recently submitted changes to its market rules to encourage energy storage, as required by an order from the Federal Energy Regulatory Commission (Order No. 841). The filing prevents energy storage resources from participating in the wholesale markets if they also participate in retail compensation programs. We submitted comments explaining how this participation barrier is inconsistent with FERC’s requirements and should be changed.

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  • Public Comments

    Comments on FERC’s Potential Reforms to PJM Capacity Market

    November 6, 2018

    After suggesting that state policies subsidizing clean energy are distorting capacity markets, the Federal Energy Regulatory Commission (FERC) is exploring reforms to the capacity market in PJM – the grid operator serving 13 states and Washington D.C. FERC’s reforms have the potential to undermine state policies that address climate change, such as Renewable Energy Credits and Zero Emissions Credits (we discuss this issue in depth in a recent report). We submitted comments to FERC and reply comments on the proposals.

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  • Public Comments

    Comments on New Jersey’s Energy Master Plan

    October 15, 2018

    New Jersey is revising its Energy Master Plan (EMP) for 2019. In advance of the first draft of the plan, the New Jersey Board of Public Utilities, along with other state agencies, formed a committee to engage with stakeholders on the contours of the new plan. We submitted comments to the EMP Committee with a number of recommendations. Specifically, in drafting the 2019 EMP, we advise the Committee to consider grid resilience in a holistic manner and apply cost-benefit analysis to resilience plans and investments; adopt a granular approach to rate design, rather than use net metering; and design an incentive structure for energy storage operators to ensure that the use of energy storage systems reduces greenhouse gas emissions. These recommendations draw upon several of our recent publications on electricity policy, including reports on grid resilience and energy storage, and an academic article, also on energy storage. The first draft of the EMP is scheduled to be released this winter.

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