Recent Projects

New York State is seeking to refine its method for compensating distributed energy resources (DERs) based on the value that they provide, including their potential to reduce local air pollution and greenhouse gas emissions. Together with a group of government agencies, non-governmental community and environmental organizations, academic centers, and clean energy businesses, we submitted a report that describes the work of an informal, stakeholder-led Environmental / Environmental Justice Value Subgroup, which was formed to identify methods for calculating the environmental and public health value of avoided air pollution caused by DER injections in New York State. As part of that filing, we also submitted our report, Valuing Pollution Reductions, which serves as a general guide for state regulators interested in calculating the environmental and public health value of avoided air pollution caused by DER injections.We also presented the results of this report to NYS DPS Staff.

The Department of the Interior is proposing to extend leasing and operations at New Mexico’s San Juan mine by 15 years, producing up to 53 million additional tons of coal that will release 97.5 million tons of greenhouse gas emissions when combusted. In our comments to Interior on its draft environmental impact statement (DEIS) for the mine’s lease extension, we criticize Interior’s failure to fully account for the climate effects related to the project by monetizing the damage these emissions will cause. This refusal leaves the public and decisionmakers in the dark about the climate effects of the project, and is arbitrary given that the agency relies on the project’s monetized benefits to justify its action.

As the Bureau of Land Management (BLM) considers opening Alaska’s Arctic National Wildlife Refuge for oil and gas leasing, pursuant to language in the 2017 Tax Act, our comments explain that development of oil and gas in the Arctic Coastal Plain would pose serious threats to this delicate, pristine ecosystem. In preparing an Environmental Impact Statement (“EIS”) for this potential lease sale, BLM must consider the many factors that weigh strongly against any leasing or development in the Refuge.

Our policy director, Jayni Hein, published a new op-ed in U.S. News & World Report on the Interior Department’s failure to protect the public interest in fossil fuel leasing decisions. In addition, she submitted the op-ed as public comments to Interior’s Royalty Policy Committee and gave verbal remarks at its meeting on June 6, 2018. Hein argues that Interior is required by law to earn “fair market value” for the use and development of public natural resources, and that providing royalty rate reductions and other undue concessions would inappropriately transfer public revenue to fossil fuel industry stakeholders.

New York State is considering setting a procurement goal of 2,400 MWs worth of new offshore wind generation facilities by 2030. In our comments to the New York Public Service Commission, we encourage the Commission to continue the use of the Social Cost of Carbon to value the benefits of avoiding greenhouse-gas emissions in the state’s Offshore Wind Policy. We also explain that the proposal to pay for the benefits of offshore wind outside of the wholesale markets is a reasonable way to move closer to internalizing the external costs of carbon-dioxide emissions and other pollution.

EPA has indicated that it intends to weaken its emission standards for light-duty vehicles and that it may attempt to revoke California’s ability under the Clean Air Act to maintain these protective standards. Our comments to California’s Air Resources Board (CARB) discuss the substantial economic benefits that California would gain from maintaining the more stringent standards that both EPA and California currently require. We submitted our report, Analyzing EPA’s Vehicle-Emissions Decisions, to CARB to provide additional information on why weakening vehicle emission standards set for years 2022-2025 would be economically irrational.

New York State is in the process of reforming its payment system for distributed energy resources (DERs), such as rooftop solar panels, away from a net energy metering policy that compensated these resources at retail electricity rates. Our comments to the New York Public Service Commission encourage the state to move towards rate designs that better reflect the underlying costs of generating, transmitting, and distributing electricity, including environmental externalities for all customers, including those who do not own DERs. Our joint comments with other stakeholders also offer high-level principles for rate design that can help achieve the state’s clean energy goals.

EPA’s Science Advisory Board provides independent scientific guidance to the Agency. Our oral comments to EPA’s Science Advisory Board encourage the Board to review the science and economics behind EPA’s proposed deregulatory actions. We ask the Board to consider our recent paper on the full value of reducing particulate matter (PM) pollution in evaluating the benefits of reducing PM below the current National Ambient Air Quality Standards. Our comments also ask the Board to review EPA’s manipulation of economics in order to downplay the climate harms of its deregulatory actions. Specifically, we discuss manipulations of the 2016 Interagency Working Group’s Social Cost of Carbon estimates. We argue that EPA’s new “interim” estimate for the Social Cost of Carbon ignores the global nature of climate damage and obscures the devastating effects that climate change will have on future generations, and we strongly encourage review of the methods used to reach this new “interim” estimate.

The Bureau of Ocean Energy Management (BOEM) is responsible for leasing offshore areas for energy development, including areas for wind energy. The agency has so far awarded 13 commercial offshore wind leases, totaling about 17 GW of capacity. In response to its request for feedback on the future of its offshore wind program for the Atlantic Outer Continental Shelf, our comments to BOEM suggest steps toward developing a robust offshore wind program that will deliver benefits to the public for decades to come.

We recently submitted two sets of joint comments to the Bureau of Land Management on the agency’s failure to monetize the climate effects of two fossil fuel projects in their NEPA analyses. Our comments explain why each of BLM’s reasons for not using the social cost of greenhouse gases in these NEPA assessments fails, and how the agency leaves the public and decisionmakers in the dark about the climate effects of the project, in violation of NEPA.