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  • Comments to FERC on Transmission Incentives

    The Federal Energy Regulatory Commission proposed changes to its electric transmission incentives, which aim to spur the deployment of technologies that enhance reliability, efficiency, and capacity of transmission facilities. We submitted comments identifying significant problems with the proposal, including its reliance on a benefit-cost ratio for project selection.

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  • Energy Transition, Distributed Energy Resources, and the Need for Information Cover

    Energy Transition, Distributed Energy Resources, and the Need for Information

    Modernizing the U.S. power grid to advance the clean energy transition, to increase the deployment of new technologies such as smart and controllable appliances, electric vehicles, and energy storage, and to reduce emissions is the mainstream discussion in today’s utility regulation. Policymakers around the country are implementing various types of reforms ranging from technology mandates to new tariffs aimed at unlocking competitive forces to achieve their policy goals. We briefly overview the potential information problems that can arise, discuss the importance of information in energy policy design for DER deployment, and then conclude by suggesting directions for future policy research.

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  • Comments to FERC on NERA Net Metering Petition

    The New England Ratepayers Association (NERA) recently petitioned the Federal Energy Regulatory Commission (FERC) to effectively overturn net metering policies nationwide. While FERC has previously and definitively answered the jurisdictional question concerning net metering, NERA asserts without evidence that controversy persists. We submitted comments describing the flaws of NERA’s argument and urging FERC to reject the petition.

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  • Comments to Colorado PUC on Valuing Distributed Energy Resources

    The Colorado Public Utilities Commission (PUC) is exploring options for valuing distributed energy resources (DERs) in various contexts, including infrastructure planning, performance-based ratemaking, and others. We submitted comments identifying metrics that capture the value of DERs and suggesting how the PUC can employ those metrics to maximize benefits to the grid and society.

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  • Comments to Rhode Island on Carbon Pricing Study

    Rhode Island is undertaking a study to understand what a state carbon pricing scheme would look like and how it would interact with the state’s participation in the Regional Greenhouse Gas Initiative and the Transportation and Climate Initiative. We submitted comments that support the exploration of implementing a multisectoral carbon price and recommend that the state study a scenario that uses the federal Interagency Working Group’s Social Cost of Carbon.

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  • Carbon Pricing in Wholesale Energy Markets Cover

    Carbon Pricing in Wholesale Energy Markets

    Conference Brief

    Policy Integrity and the Nicholas Institute for Environmental Policy Solutions at Duke University convened a conference on March 3, 2020, to discuss current, and potential future, approaches to carbon pricing in wholesale markets. This brief highlights some of the major points of discussion and suggests open questions for future study. 

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  • Regulating the Energy Transition Cover

    Regulating the Energy Transition

    FERC and Cost-Benefit Analysis

    This article, published in the Columbia Journal of Environmental Law, argues that, FERC’s management of this transition would be significantly enhanced if it embraced cost-benefit analysis—including accounting for important indirect costs and benefits such as the effect on climate change—to guide its decisionmaking. Changing course and adopting cost-benefit analysis will allow FERC to manage the energy transition while maximizing social welfare, enhancing transparency and accountability, and mitigating legal and political risk

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  • Comments to New Jersey BPU on Resource Adequacy Alternatives

    The New Jersey Bureau of Public Utilities (BPU) requested public input on its investigation of resource adequacy alternatives. We submitted comments encouraging the New Jersey BPU to recognize important uncertainties affecting the proceeding, consider a broad range of costs of pursuing a Fixed Resource Requirement, and explore the possibility of a carbon pricing program in addition to participation in the Regional Greenhouse Gas Initiative.

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  • Comments to the Colorado Public Utilities Commission on Electricity Rule Changes

    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. We also submitted comments and reply comments on additional rule revisions, building on our original comments to further describe how the Commission can best express and apply the Social Cost of Greenhouse Gases.

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  • Amicus Brief on EPA’s Clean Power Plan Replacement Rule

    Last year, the Environmental Protection Agency (EPA) replaced the Obama Administration’s Clean Power Plan, which sought substantial cuts in greenhouse gas emissions from power plants, with the so-called Affordable Clean Energy (ACE) rule, a far weaker policy that will, at best, yield modest reductions below business-as-usual emissions and, at worst, increase pollution from the electric sector. We filed an amicus brief in the U.S. Court of Appeals for the D.C. Circuit highlighting three key errors in EPA’s rationale for repealing the Clean Power Plan. Specifically, we explain, EPA misstates regulatory precedent and Clean Air Act legislative history supporting the Clean Power Plan and disregards the substantial harms that the ACE Rule will cause.

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