Recent Projects

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.

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.

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.

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.

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. 

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.

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.

The Department of Energy (DOE) proposed changes to the Process Rule for prescribing energy conservation standards. We submitted comments and additional comments explaining how certain proposed changes violate both DOE's statutory mandate and the principles of rational rulemaking. We emphasize that the significance of energy savings must be weighed by considering all important costs and benefits.

The Department of Energy (DOE) recently asked for input on energy conservation standards for certain electrical grid equipment. We submitted comments encouraging DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.

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.