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Public Comments
Comments to Rhode Island on Carbon Pricing Study
Rhode Island is undertaking a study to understand what a state carbon pricing scheme would look like and how it would interact with the state’s participation in the Regional Greenhouse Gas Initiative and the Transportation and Climate Initiative. We submitted comments that support the exploration of implementing a multisectoral carbon price and recommend that the state study a scenario that uses the federal Interagency Working Group’s Social Cost of Carbon.
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Public Comments
Comments to EPA Science Advisory Board on Economic Analysis Guidelines
The Environmental Protection Agency’s chartered Science Advisory Board (SAB) invited the public to comment on its new draft Guidelines for Preparing Economic Analyses. We submitted multiple sets of comments covering different portions of the guidelines.
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Public Comments
Comments to New Jersey BPU on Resource Adequacy Alternatives
The New Jersey Bureau of Public Utilities (BPU) requested public input on its investigation of resource adequacy alternatives. We submitted comments encouraging the New Jersey BPU to recognize important uncertainties affecting the proceeding, consider a broad range of costs of pursuing a Fixed Resource Requirement, and explore the possibility of a carbon pricing program in addition to participation in the Regional Greenhouse Gas Initiative.
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Public Comments
Joint Comments to CTFC on Climate-Related Market Risk
The Commodity Futures Trading Commission (CTFC) requested public input on issues relevant to its Climate-Related Market Risk Subcommittee. We submitted joint comments highlighting the significant financial risks that climate change poses and emphasizing that an economy-wide price on carbon emissions is the regulatory tool that will be the most effective in mitigating a climate-related financial crisis.
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Public Comments
Comments to PHMSA on Data Collection from Pipeline Accidents
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing to gather additional data on pipeline accidents and fires, including data on injuries, property damage, and loss of natural gas. We submitted comments supporting PHMSA’s efforts to better assess the social cost of accidents and encouraging the agency to estimate greenhouse gas emissions that result from pipeline fires.
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Public Comments
Comments to SEC on Regulation S-K and Climate Risk
The Securities and Exchange Commission (SEC) proposed a rule modifying Regulation S-K, which governs reporting requirements for public companies. We submitted comments focusing on the SEC’s failure to require disclosure of risks relating to climate change. Climate risks are economy-wide impacts in which the future increasingly diverges from past experience, and predicting such risks requires more granular data than is typically disclosed in financial reporting. We suggest that the SEC adopt a more specific line-item approach to climate risk reporting, similar to the framework suggested under the Task Force on Climate-Related Financial Disclosures.
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Public Comments
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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Public Comments
Comments to FERC on Lamar County Natural Gas Project
The Federal Energy Regulatory Commission’s (FERC) environmental assessment estimates that the Lamar County Expansion Project would result in 3.87 million metric tons of greenhouse gases from downstream emissions. We submitted comments suggesting that FERC monetize climate impacts using social cost of carbon estimates. The proposed natural gas project would result in over $200 million in annual climate costs.
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Public Comments
Comments to EPA on Coal Combustion Residuals Rule
Coal combustion residuals, commonly known as coal ash, are the residual substances that remain after burning coal. They contain several chemicals that are toxic to human health, including arsenic, boron, lead, and mercury. The Environmental Protection Agency (EPA) proposed a rule that amends the regulatory framework for the disposal of coal ash. We submitted comments in January detailing how EPA fails to analyze the forgone benefits of the regulatory changes, which extend deadlines and eligibility for facilities that lack appropriate disposal capacity. We also submitted comments in April focusing on the second part of EPA's proposal, which fails to assess the forgone benefits of allowing facilities to seek approval for alternative basin liners.
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Public Comments
Comments to the Colorado Public Utilities Commission on Electricity Rule Changes
The Colorado Public Utilities Commission is amending its rules relating to utilities, electric resource planning, and renewable energy standards. We submitted comments explaining why the Commission should use Social Cost of Greenhouse Gases estimates to monetize the externalities of carbon pollution. Our recommendations include rule revisions and new language that will help include monetized estimates of climate impacts in all relevant decisionmaking. We also submitted supplemental comments on additional rule revisions, building on our original comments to further describe how the Commission can best express and apply the Social Cost of Greenhouse Gases.
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