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  • Comments to FERC Supporting Petition for Technical Conference on Carbon Pricing

    Advanced Energy Economy, the Electric Power Suppliers Association, and a diverse group of other stakeholders recently filed a petition for the Federal Energy Regulatory Commission (FERC) to hold a technical conference on carbon pricing in organized wholesale electricity markets. We have worked extensively to study and promote carbon pricing, publishing a comprehensive report and several academic articles. We also hosted a conference that brought together experts and stakeholders to discuss related legal, economic, and policy questions. Our comments to FERC highlight our previous work on wholesale market carbon pricing and express our support for the requested technical conference.

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  • Carbon Pricing in Wholesale Electricity Markets Cover

    Carbon Pricing in Wholesale Electricity Markets

    An Economic and Legal Guide

    This report explains how carbon-pricing rules in organized wholesale electricity markets can improve economic efficiency. It then explores the economic principles and legal requirements for RTOs, states, and the Federal Energy Regulatory Commission to consider when implementing a carbon-pricing rule in organized wholesale electricity markets. And it identifies several policy-design approaches that, to varying degrees, meet those economic principles and are likely to be found legally permissible.

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  • Comments to DOE on Changes to Energy Conservation Process Rule

    The Department of Energy (DOE) proposed to change the way it selects energy efficiency standards by excluding certain efficiency levels as not "economically justified" on the grounds of effects to small businesses, market competition, or consumer convenience.The change, however, would allow DOE to irrationally and inconsistently give preference to whichever subset of economic impacts the agency wants to focus on in order to deem standards that otherwise achieve net benefits as instead being not economically justified. We submitted comments explaining how the proposal will not ensure consistent consideration of statutory factors.

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  • Comments on Connecticut’s Study of the Value of Distributed Energy Resources

    Connecticut’s Department of Energy and Environmental Protection (DEEP) and Public Utilities Regulatory Authority (PURA) are conducting a study to determine how it can best compensate distributed energy resources, like solar panels and residential battery installations, which can provide provide significant value to the grid. DEEP and PURA’s study involves an electric system dispatch simulation model and various DER technology use cases. We submitted comments on the model’s outputs and how they can be improved to better serve the study.

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  • Comments to DOE on Energy Conservation Standards for Refrigerators and Freezers

    The Department of Energy requested input on its analysis of energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers. We submitted comments encouraging DOE to, as it has in the past, monetize the full climate benefits of greenhouse gas emission reductions.

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  • Our Work on State Zero-Emission Credits Programs

    Several states have determined that ensuring the viability of zero-emission electricity generation from nuclear power is critical to mitigating the impacts of climate change especially in the short term while states work to meet aggressive new clean energy goals. Through comments and amicus briefs, we’ve been involved in those efforts in both New York and New Jersey.

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  • Managing the Future of the Electricity Grid: Modernizing Rate Design Cover

    Managing the Future of the Electricity Grid: Modernizing Rate Design

    This article, published in the Harvard Environmental Law Review, argues that the electricity sector is at a critical juncture, and that a shift to a paradigm with a long-term vision that includes better, economically efficient rate designs is necessary if we want to realize the clean energy future that the modern grid promises us.

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  • Comments to DOE on Energy Conservation Standards for Fluorescent Lamps

    The Department of Energy proposed to not increase the efficiency of fluorescent lamp ballasts. We submitted comments noting that DOE fails to analyze the forgone emissions reductions of its proposed determination.

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  • Comments to FERC on Offshore Wind Transmission

    Due to a significant buildout of offshore wind in the mid-Atlantic as a result of falling costs and state policy commitments, new offshore transmission will be required. However, the market rules for the nation’s largest electricity grid operator, PJM, currently provide no practical path for the development of open-access transmission to connect planned but not-yet-developed offshore wind generation. We submitted comments urging the Federal Energy Regulatory Commission to eliminate barriers to these projects, lowering transmission costs and ensuring just and reasonable rates.

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  • Getting the Value of Distributed Energy Resources Right Cover

    Getting the Value of Distributed Energy Resources Right

    Using a Societal Value Stack

    Our report notes the growing presence of distributed energy resources, like solar panels and energy storage installations, and explains how they should be compensated for providing electricity services valued by utilities and their customers. Currently, 40 states use net energy metering programs to compensate DERs. We describe a promising alternative, “value stacking,” which better reflects DERs’ value, and provide suggestions for how to implement this approach.

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