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Comments to Colorado on Participation in Centralized Electricity Markets
The Colorado Public Utilities Commission is evaluating different options for electric utility participation in centralized electricity markets, as part of the Colorado Transmission Coordination Act. We submitted comments encouraging the Commission to move the state to a centralized market, which would help accomplish energy goals and would benefit generators, utilities, and customers.
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Comments to the New York Public Service Commission on Resource Adequacy
We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.
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Comments to Massachusetts on Clean Peak Energy Standards
The Massachusetts Department of Energy Resources is adopting a program that incentivizes the adoption of energy storage resources with the aim of displacing high-pollution resources during peak periods of energy use. We submitted comments that explain potential risks of energy storage integration and encourage Massachusetts to adjust its clean peak policies to maximize the emissions reduction potential of the state’s energy storage resources.
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Comments on Colorado’s Use of the Social Cost of Greenhouse Gases
The Colorado Public Utilities Commission (CPUC) proposed rule revisions to a recent clean energy bill, providing more information on how social cost of greenhouse gases (SCGG) estimates will be used. We submitted comments encouraging best practices for SCGG application that will help CPUC monetize climate externalities and weigh the costs and benefits of various decisions.
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Court Upholds New York’s Zero-Emissions Credit Program for Nuclear Power
The Albany County Supreme Court rejected a challenge to New York’s Zero-Emissions Credit (ZEC) program, which pays nuclear power plants for the value of avoided carbon emissions. The legal challenge focused largely on the state’s decision to use the Interagency Working Group’s Social Cost of Carbon (SCC) to value emissions.
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Comments to Minnesota on Electric Resource Planning and the Social Cost of Carbon
The Minnesota Pollution Control Agency and Minnesota Department of Commerce requested comments on their proposal to consider resource planning scenarios using a range of both environmental and regulatory costs. Minnesota has been a leader among states on incorporating environmental externalities into electricity policy, and our comments encourage the agencies to continue requiring the use of the social cost of carbon.
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Comments to DOE on Grid Resilience
The Department of Energy requested input on how it can enhance the resilience of electric infrastructure systems against severe weather events. We submitted comments, attaching our report on grid resilience and highlighting key takeways that may support DOE efforts to improve the power system.
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Comments to DOE on Energy Conservation Standards for Air Conditioners
The Department of Energy requested input on impact and emissions analysis for upcoming energy conservation standards. We submitted comments encouraging DOE to continue to monetize the full climate benefits of greenhouse gas emissions reductions.
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Comments on Connecticut’s Proposed Value Categories for Distributed Energy Resources
The Connecticut Department of Energy and Environmental Protection (DEEP) and Public Utilities Regulatory Authority (PURA) have proposed several quantitative and qualitative value categories it intends to examine in its study of the value of DERs. We submitted comments supporting their inclusion of avoided emissions costs, which covers both greenhouse gas emissions and ambient air pollutants, as a value category. We also encourage DEEP and PURA to include electricity system resilience among the quantifiable benefits of DER deployment.
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Comments to DOE on Energy Conservation Standards for Metal Halide Lamps
The Department of Energy (DOE) recently asked for input on energy conservation standards for metal halide lamp fixtures. We submitted comments encourage DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.
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