Recent Projects

The Colorado Public Utilities Commission (PUC) is exploring options for valuing distributed energy resources (DERs) in various contexts, including infrastructure planning, performance-based ratemaking, and others. We submitted comments identifying metrics that capture the value of DERs and suggesting how the PUC can employ those metrics to maximize benefits to the grid and society.

The Department of Energy (DOE) requested input on how it should conduct analysis of the efficiency, economic impact, and emissions of general service fluorescent lamps and incandescent reflector lamps. We submitted comments encouraging DOE to monetize the full benefits of emissions reductions using the social cost of greenhouse gases.

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.

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.

The Commodity Futures Trading Commission (CFTC) 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.

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.

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.

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 comments and reply 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.

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.

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.