Recent Projects

In a proposed set of energy efficiency standards for refrigeration systems and residential furnaces, the Department of Energy (DOE) used the Social Cost of Carbon (SCC) to value the climate benefits of more efficient technologies. DOE did not, however, incorporate this benefit for other greenhouse gases such as methane. We recently submitted joint comments with the Environmental Defense Fund, Natural Resources Defense Council, and Union of Concerned Scientists to reaffirm the use of the SCC. We also encourage the agency to monetize the benefits of other greenhouse gas reductions, such as through the existing Social Cost of Methane methodology; and to continue to update these estimates to reflect the latest science and economics on the costs of climate change damages.

We recently submitted comments to the Environmental Protection Agency on the Clean Energy Incentive Program (“CEIP”). The CEIP is a voluntary early action program to help states move forward on Clean Power Plan compliance and energy market planning. Clean Power Plan opponents have argued that it is inappropriate for EPA to move forward on its CEIP guidance because the Supreme Court has stayed the Clean Power Plan.

We recently submitted comments to the New York State Public Service Commission, responding to petitions for rehearing on the Clean Energy Standard. The Commission’s Clean Energy Standard created Zero-Emissions Credits for nuclear generation, compensating these zero-emissions generators through a valuation system based on the Social Cost of Carbon (“SCC”). Various parties submitted petitions for rehearing or clarification, and criticized the Order on a variety of grounds. Among other criticisms, challengers argue that it was inappropriate for the Commission to use the SCC to value the zero‐emission attributes of nuclear energy resources alone, and that other types of low‐ emitting resources (e.g., small hydro) should receive commensurate payments for their zero‐emission characteristics.

We recently submitted reply comments to the New York State Public Service Commission on Benefit Cost Analysis Handbooks submitted to the Commission by utility companies, within the Reforming the Energy Vision proceeding. Benefit-cost analysis will assist in determining the best resource allocations between traditional utility distribution grid investments and distributed energy resources (DER), by allowing for direct comparison. These Handbooks will help ensure that the utilities’ benefit-cost analyses will help to select investment options that will maximize net benefits to the public.

As distributed energy resources (DER) become more common and play a larger role in helping meet clean energy targets, many states are increasing their focus on the valuation and compensation of these resources. The National Association of Regulatory Utility Commissioners (NARUC) is creating a manual to assist states with these key policy questions. We recently submitted comments to NARUC’s Staff Subcommittee on Rate Design to help ensure that the manual is complete, accurate, and unbiased.

In 2015, New York State announced its Clean Energy Standard, an ambitious mandate to boost clean energy. We have submitted numerous comments to the New York State Public Service Commission, suggesting several changes in the design of this Standard to ensure that the state’s policy goals can be met in the most-cost effective manner. In its final order, the Commission adopted several of our suggested changes. Most notably, the Commission relied on our comments in deciding to calculate zero-emission credit payments based on the Social Cost of Carbon. This marks a major success in our ongoing efforts to encourage government agencies to use the Social Cost of Carbon as a tool when designing policy.

We recently submitted comments to the New York State Department of Public Service Staff regarding their Responsive Proposal for Preserving Zero-Emissions Attributes. This Proposal offers recommendations on how to achieve New York’s clean energy target: 50 percent of all electricity used in the state by 2030 should be generated by renewable energy sources.

We recently submitted comments to the U.S. Securities and Exchange Commission on business and financial disclosures related to environmental risk.

On July 6, Jayni Hein testified at a House Natural Resources Committee hearing on the “Innovation in Offshore Leasing Act.” The hearing, held by the Subcommittee on Energy and Mineral Resources, focused on H.R. 5577, a bill that would amend the Outer Continental Shelf Lands Act to allow internet-based offshore oil and gas lease sales, among other measures. Hein’s testimony covered four main topics, suggesting that the Department of the Interior should: continue to increase transparency and public participation in the offshore leasing process; improve the regulations that underlie the Bureau of Ocean Energy Management’s (BOEM’s) five-year planning process; build on recent progress addressing environmental, social, and economic uncertainty in its five-year Program and lease sales; and advance efforts to account for the environmental and social costs of fossil fuel leasing through royalty rate and other fiscal reform. Hein’s testimony elaborated on some of the arguments from her recent Alaska Law Review article and recent comments to BOEM.

We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values.