Recent Projects

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.

The California Public Utilities Commission (CPUC) is developing a comprehensive policy for integrating Distributed Energy Resource (DERs), like rooftop solar, into its energy system. A March 2018 administrative law judge ruling heavily cited our earlier comments in laying out a revised plan to require the state’s utilities to conduct a societal cost test to help compare the net benefits of different DER technologies. We submitted comments to the CPUC commending the agency for its revisions to the proposed analysis and recommending additional improvements.

In 2016, the New York Public Service Commission adopted the Clean Energy Standard, an ambitious plan to increase renewable generation to 50% of the market by 2030. While working toward that goal, the State found it was necessary to pay nuclear generators through a zero-emissions credits (ZECs) system, as compensation for the value they provide in avoiding emissions. The State found that this would help guard against an increase in pollution if the nuclear generators were to close. Our amicus brief to the Supreme Court of New York in Albany County argues that the Commission’s decision to base ZEC prices on the Social Cost of Carbon (SCC) was reasonable.

California has legislation authorizing its Air Resources Board (ARB) to extend its cap-and-trade program for carbon emissions. This extension, while defining much of the program’s structure, asks ARB to develop some design features through a regulatory process and public feedback. California’s most recent changes to the plan are consistent with our previous comments on the program, and they place California on the path to internalizing the cost of climate change from carbon emissions. Our most recent set of comments encourage ARB to continue to set the price ceiling for carbon permits at least as high as the Social Cost of Carbon set by the Interagency Working Group in 2016, as it does in its Concept Paper on carbon pricing. We also encourage ARB to allocate preferentially any unsold carbon allowances to the price ceiling, rather than to a lower price.

California has long been a trendsetter in clean energy policy, and our input helped inform the state’s approach for evaluating distributed energy resources (DERs), such as rooftop solar installations. The state’s new approach, which will quantify the environmental benefits of DERs, could help influence other policies around the country, boosting the growth of clean energy sources. Our comments to the California Public Utilities Commission were heavily cited in a March 2018 administrative law judge ruling, which, if adopted by the Commission, would require utilities to conduct a societal cost test to determine the cost-effectiveness of DERs.

The Colorado Public Utilities Commission is revising their electricity resource planning process. Our comments to the Commission suggest legal language for incorporating externalities, like the climate effects of greenhouse gas emissions, into the state’s electricity policy. We also explain why the Social Cost of Carbon, as developed by the federal government in 2016, is the best tool for incorporating the externalities of carbon emissions into policy. Our response comments rebut the state electric utility’s faulty arguments against using the social cost of carbon in this process, and supports the use of cost-benefit analysis in determining the best policy option.