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  • New York Clean Energy Standard - White Paper Comments

    The 2015 New York State Energy Plan set one of the most ambitious clean energy targets in the nation: 50 percent of all electricity used in the state should be generated by renewable energy sources. The Department of Public Service Staff recently released a White Paper on the Clean Energy Standard, with recommendations on how to achieve this ambitious goal. We submitted comments to the New York State Public Service Commission, outlining some additional steps that can help ensure that the Clean Energy Standard is not excessively costly, and is effective in achieving all of its policy goals.

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  • Comments on Net Metering and Distributed Energy Valuation in New York

    We recently submitted comments to the New York Public Service Commission on how the Commission should develop an interim successor to its net metering policy, and how distributed energy resources should be valued in the future. We filed the comments jointly with the Environmental Defense Fund. To begin to move the retail electricity markets toward efficient and accurate recognition of the value of distributed energy resources, we suggest that the Commission should enhance its existing net energy metering policy to align compensation with the system benefits provided by distributed energy resources; establish a fully unbundled retail price structure; and specifically account for the environmental benefits of distributed energy resources in future pricing structures.

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  • Balancing on the Grid Edge Cover

    Balancing on the Grid Edge

    Regulating for Economic Efficiency in the Wake of FERC v. EPSA

    This new article from senior attorney Denise Grab is featured in a special edition of the Harvard Environmental Law Journal that focuses on the Supreme Court’s FERC v. EPSA case.

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  • Brief for Clean Power Plan Litigation

    We recently submitted an amicus brief in the litigation over the EPA’s Clean Power Plan, which regulates carbon dioxide emissions from the power sector. A group of coal companies and states is asking the U.S. Court of Appeals for the D.C. Circuit to strike down the rule, arguing that it represents an unprecedented expansion of the EPA’s regulatory authority. Our brief shows that, in fact, there are regulatory precedents for every aspect of the rule that petitioners claim is unprecedented. Our analysis of past EPA regulations and court rulings reveals that the Clean Power Plan is consistent with decades of Clean Air Act practice under administrations of both parties.

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  • Managing the Future of the Electricity Grid: Distributed Generation and Net Metering Cover

    Managing the Future of the Electricity Grid: Distributed Generation and Net Metering

    As distributed energy generation is becoming increasingly common, the debate on how a utility’s customers should be compensated for the excess energy they sell back to the grid is intensifying. This article provides a thorough analysis of the benefits and the costs of distributed generation and highlights the analytical flaws and missing elements in the competing positions and in all the existing policies.

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  • Clean Power Plan - Comments on Federal Plan/Model Trading Rules

    Concurrently with issuing its final Clean Power Plan to limit greenhouse gas emissions from existing power plants, the EPA issued a set of proposed federal plan requirements and model trading rules to provide states guidance as they determine their strategies to comply with the Clean Power Plan. We recently submitted comments to the agency on how these guidelines can be improved to best reduce compliance costs and promote effectiveness of the plan.

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  • Familiar Territory Cover

    Familiar Territory

    A Survey of Legal Precedents for the Clean Power Plan

    In this essay, we highlight a wide variety of regulations from the Clean Air Act’s forty-five-year history that provide substantial precedent for the flexible design of the Clean Power Plan.

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  • Comments on New York State Energy Policy

    We recently submitted comments on New York State’s Reforming the Energy Vision (REV) initiative

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  • Revesz Testifies at House Hearing on Clean Power Plan

    Richard Revesz testified at today’s House Energy & Commerce Committee hearing, “EPA’s CO2 Regulations for New and Existing Power Plants: Legal Perspectives.”

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  • Comments on New York State’s “Reforming the Energy Vision” Initiative

    We recently submitted comments to the New York State Public Service Commission regarding the Reforming the Energy Vision (REV) initiative, which seeks to spur clean energy innovation and improve consumer choice and affordability in New York State. The Commission sought comments on how best to develop a cost-benefit analysis framework to evaluate utility proposals within the REV and related proceedings. Our comments addressed the consideration of externalities and the social cost of carbon in the Commission’s cost-benefit analysis.

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