Recent Projects

Net metering, the predominant approach to compensating distributed solar generation in the U.S., essentially pays households with solar panels a flat retail rate for every kilowatt hour they send back to the grid. In response to the Department of Energy’s request for information on the costs and benefits of net energy metering, we submitted Richard Revesz and Burcin Unel’s law review article on net metering and distributed electricity generation. The paper analyzes the benefits and costs of distributed generation, and identifies ways for state policy to better match consumer compensation for solar generation with the energy system and environmental benefits that it provides. It also includes information that is relevant to the RFI including the identification and categorization of the costs and benefits of net energy metering policies.

Energy Secretary Rick Perry’s controversial proposal to subsidize coal and nuclear plants could have terrible consequences for consumers and public health, as our recent comments and op-ed in US News highlight. In September, Perry asked the Federal Energy Regulatory Commission (FERC) to adopt a new rule that would guarantee coal and nuclear plants their full costs plus a profit, so long as they keep 90 days of fuel on site. Perry claims that these “fuel-secure” plants ensure grid reliability and resilience, but neither he nor FERC adequately define these terms or explain why such a measure is justified.

Nevada’s Senate Bill 65, passed in 2017, directs the state’s Public Utilities Commission to prioritize the sources of electricity that provide the greatest economic and environmental benefits, including considering the potential costs of carbon, when reviewing utilities’ resource plans. Our joint comments with Western Resource Advocates and the Environmental Defense Fund offer guidance to the Commission on how to evaluate the potential costs of carbon. Specifically, we recommend that the Commission should require the utilities’ resource plans to use the Social Cost of Carbon as developed by the federal government in 2016 to evaluate the potential costs of carbon associated with different electricity sources. We also submitted joint comments replying to stakeholder feedback, offering specific feedback on how the Commission can modify its regulations to accomplish the intent of the bill.

We recently submitted comments to California’s Public Utilities Commission, focused on the economic analysis used in its longer-term energy planning process across utilities. We ask the Commission to exercise caution in coordinating or consolidating this planning with other energy-related proceedings, as different proceedings have different goals and statutory requirements.

California’s state government is moving forward on electricity and climate policy, likely setting a blueprint for future state and federal action. We submitted comments to the California Public Utilities Commission (CPUC) on factual disputes flagged by stakeholders, related to how utilities will use cost-benefit analysis in decisionmaking. We encouraged staff at CPUC to use the Social Cost of Carbon for its interim greenhouse gas adder, use a 3% discount rate for future damages, include other environmental externalities like air pollution in its analysis, and continue considering societal costs to ensure that the benefits justify the costs of a proposed policy.

We recently submitted comments to the California Public Utilities Commission on their proposal for an interim greenhouse gas adder. The proposal was for an adder that starts at $0 in 2017 and increases linearly to $250 in 2030. We support the use of a greenhouse gas adder. However, our comments suggest that the Commission instead use an adder based on the Interagency Working Group’s Social Cost of Carbon (“SCC”).

We recently submitted a second set of comments to the California Air Resources Board on its 2017 Climate Change Scoping Plan Update. These comments build on those we submitted in December to ARB on the discussion draft of the scoping plan.

The California Public Utilities Commission proposed using a Societal Cost Test to help select the combination of distributed energy resource projects that will result in the greatest net benefits to society. We counter the feedback that some stakeholders gave on implementing this approach in our reply comments. We argue that the Commission should: (1) expand its discussion of the legal basis for applying a societal cost test that includes a full range of externalities; (2) use the damage cost approach to determine the value of greenhouse gas abatement, rather than the proposed abatement cost approach; and (3) apply a societal discount rate to the analysis.

We recently submitted comments to the California Public Utilities Commission (CPUC) on their proposal to develop a more robust societal cost test to evaluate the cost-effectiveness of distributed energy resources (DERs). California has been a national leader in addressing the challenges associated with DER integration, and this proceeding will help the state to reform their cost-effectiveness framework.

The Massachusetts Department of Environmental Protection (“MassDEP”) has proposed a set of regulations to limit the greenhouse gas emissions from electric power plants, natural gas pipelines, government-owned transportation equipment, and utility-owned switchgear equipment. MassDEP has also proposed a new requirement that retail sellers of electricity purchase gradually increasing amounts of clean energy, along with non-binding targets for greenhouse gas emissions from the transportation sector.

In our comments to MassDEP, we offer three suggestions to ensure these regulations cut global greenhouse gas emissions in a cost-effective way. First, we encourage MassDEP to prevent potential emissions leakage to other states in the Northeast’s Regional Greenhouse Gas Initiative (“RGGI”) program. Second, we recommend the regulations should be technology-neutral and use a flexible compliance system. Third, we recommend enforceable emissions limits on the transportation sector rather than non-binding targets, especially considering that the state’s emissions from transportation sector are almost twice those of the electric sector.