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Recent Projects

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  • Public Comments

    Comments to Iowa Utilities Board on Energy Efficiency Program Benefits

    June 5, 2019

    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.

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  • Public Comments

    Comments to DOE on Energy Conservation Standards for Small Motors

    May 24, 2019

    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.

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  • Public Comments

    Comments to FERC on PJM Reserve Market Reforms

    May 15, 2019

    PJM, the regional organization that manages wholesale electricity and the transmission grid in 13 eastern states, recently proposed a number of changes to its operating reserve market in an effort to improve its pricing mechanism. We submitted comments to the Federal Energy Regulatory Commission (FERC) supporting PJM’s proposal and recommending additional changes.

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  • Public Comments

    Comments on Georgia’s Electric Utility Resource Plan

    May 14, 2019

    Georgia Power Company recently published its 2019 electric utility resource plan, which includes projected future costs of different energy generation programs. We submitted comments asking that Georgia Power more clearly quantify and monetize the greenhouse gas emissions of electricity generation alternatives.

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  • Public Comments

    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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