Recent Projects

The Nevada Public Utilities Commission recently released a proposed regulation to implement Senate Bill 65, which directs the PUC to give preference to those measures and sources of supply that provide the greatest economic and environmental benefit to the State. In our joint comments with Western Resource Advocates and Environmental Defense Fund, we express our support for these revisions to Nevada’s resource planning regulations. Specifically, we support the Commission’s application of the Interagency Working Group (IWG) Social Cost of Carbon (SCC) estimates to calculate the Present Worth of Societal Costs in Nevada, as reflected in the proposed regulation. In addition, we update the PUC on the use of the IWG SCC estimates in other states, including California, Colorado, Minnesota, New York and Washington State.

In April 2018, the Federal Energy Regulatory Commission (FERC) issued a notice of inquiry on how to revise its policy on certifying the construction and operation of interstate natural gas transportation facilities. In the nineteen years since FERC’s existing policy statement was released, there have been significant advances in the understanding and measurement of climate change and other environmental effects of natural gas production, transportation, and consumption. Our comments suggest clarifications and improvements to FERC’s NEPA and Natural Gas Act analyses that will better inform policymakers and the public about the environmental effects of proposed projects. We also submitted joint comments on the appropriate use of the social cost of carbon in the interstate natural gas facilities certification processes, including why and how greenhouse gas emissions should be monetized in FERC’s NEPA and Natural Gas Act analyses.

PJM Interconnection (PJM), the electric grid and wholesale market operator in 13 states and Washington D.C., currently has a market design that leads to over-procurement of electric generating capacity, particularly from generation resources that are able to provide capacity throughout the year. This inefficient market design raises capacity costs and suppresses the participation of resources, such as wind, solar, and natural gas, whose generating capacity varies by season. The Federal Energy Regulatory Commission (FERC) recently held a technical conference to seek feedback on how PJM can redesign its capacity market to better facilitate participation of these seasonal resources. Our comments to FERC argue that replacing or supplementing the current annual-only capacity product with seasonal capacity products would improve the efficiency of the PJM capacity market. In addition, we suggest changes in the capacity market participation rules for wind, solar, and other intermittent resources.

New York State is seeking to refine its method for compensating distributed energy resources (DERs) based on the value that they provide, including their potential to reduce local air pollution and greenhouse gas emissions. Together with a group of government agencies, non-governmental community and environmental organizations, academic centers, and clean energy businesses, we submitted a report that describes the work of an informal, stakeholder-led Environmental / Environmental Justice Value Subgroup, which was formed to identify methods for calculating the environmental and public health value of avoided air pollution caused by DER injections in New York State. As part of that filing, we also submitted our report, Valuing Pollution Reductions, which serves as a general guide for state regulators interested in calculating the environmental and public health value of avoided air pollution caused by DER injections.We also presented the results of this report to NYS DPS Staff.

New York State is in the process of reforming its payment system for distributed energy resources (DERs), such as rooftop solar panels, away from a net energy metering policy that compensated these resources at retail electricity rates. Our comments to the New York Public Service Commission encourage the state to move towards rate designs that better reflect the underlying costs of generating, transmitting, and distributing electricity, including environmental externalities for all customers, including those who do not own DERs. Our joint comments with other stakeholders also offer high-level principles for rate design that can help achieve the state’s clean energy goals.

The Federal Energy Regulatory Commission (FERC) requested feedback from regional electricity regulators on the state of resilience in wholesale markets, efforts underway to ensure grid resilience, and opportunities for future improvement. Their responses make clear that while grid resilience is an issue worthy of continued attention, there is not currently evidence to support mandatory, national or even regional action to address acute resilience concerns. Our comments to FERC argue that it should not seek a “one-size-fits-all” solution for all Regional Transmission Organizations and Independent System Operators (RTOs/ISOs), nor should it consider resilience a “catch-all” concept that opens the door to otherwise unsupported or unnecessary actions.

PJM Interconnection, L.L.C (PJM), a regional electricity transmission organization serving 13 states and Washington D.C., recently submitted a proposal to the federal government requesting changes that would “mitigate” the impact of state climate and energy policies on electricity markets. In our comments to the Federal Energy Regulation Commission (FERC), we argue that PJM’s proposals rest on a faulty premise that state public policies are distorting the economic efficiency of capacity market price signals, which heavily affect how generators enter and exit the market.