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  • Issue Briefs

    Understanding EPA’s Enforcement and Compliance Policy During the COVID-19 Pandemic

    May 21, 2020

    This issue brief summarizes EPA's enforcement and compliance policy in light of COVID-19, describing its significance and clarifying its contours. The policy opens the door to potentially problematic and harmful actions, especially on a short-term basis. 

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  • Reports

    Beneath the Surface

    April 27, 2020

    In restricting the scope of the Clean Water Act through two regulatory rollbacks, the Environmental Protection Agency and Army Corps of Engineers claim that the estimated compliance-cost savings exceed the environmental harms (in the form of forgone benefits). Yet these analyses suffer from severe methodological flaws. And correcting the analyses would very likely show that the rollbacks are net costly to society, depriving the public of potentially billions of dollars in annual forgone benefits. As detailed in this report, the agencies’ failure to meaningfully assess the substantial harms that will result from their rollbacks violates both regulatory precedent and the agencies’ legal obligations.

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  • Reports

    Carbon Pricing in Wholesale Electricity Markets

    March 25, 2020

    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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  • Academic Articles/Working Papers

    Managing the Future of the Electricity Grid: Modernizing Rate Design

    February 1, 2020

    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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  • Reports

    Look Before You Lease

    January 7, 2020

    While the Trump administration’s goal of “energy dominance” has increased the public lands available for oil and gas development, no effort has been made to modernize the leasing system, even in the face of climate change. Our report explains how option value—which accounts for the informational value gained by delaying leasing decisions—can and should be factored into the Bureau of Land Management’s land use planning processes. Accounting for option value at multiple stages of the land use planning process would significantly improve BLM’s public lands stewardship, better protect the environment, and regain some of the economic and strategic advantages it has ceded to private developers. The report also describes case studies where BLM’s failure to consider option value has led to costly litigation and missed opportunities.

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  • Policy Briefs

    Assessing the Rationale for the EPA’s Proposed Regulatory Science Rule

    December 19, 2019

    The U.S. Environmental Protection Agency (EPA) is considering a new policy that would prohibit the agency from issuing regulations that rely on studies whose underlying data are not publicly available. While the EPA claims it is pursuing this policy in the interest of transparency, we argue that such a prohibition would greatly hinder, rather than help, the rulemaking process and would likely result in undesirable regulatory outcomes that fail to maximize economic welfare.

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  • Academic Articles/Working Papers

    (Not So) Clean Peak Energy Standards

    December 10, 2019

    Growth in electricity storage has the potential to increase emissions from power generation. Concerns about this outcome are currently prompting many policies to address the issue. We study a particularly popular policy proposal called the “Clean Peak Standard” that incentivizes storage to discharge during periods of high electricity demand. The stated goal of the policy is to shift storage discharge to offset production from generators with high pollution emissions. We show that the policy is largely ineffective at achieving this emissions reduction goal. The policy reinforces existing incentives faced by storage operators, so it does not have a strong effect on discharging behavior. It is also unable to capture high-frequency changes in marginal operating emissions rates. Alternative policies, such as a carbon tax, are more effective at reducing the emissions increase caused by storage. Policymakers considering Clean Peak-style policies should instead consider these alternative policies.

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  • Reports

    Getting the Value of Distributed Energy Resources Right

    December 3, 2019

    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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  • Academic Articles/Working Papers

    Electricity Simulations on the Distribution Edge

    June 1, 2019

    The electric distribution grid is transitioning toward a model in which customers can themselves provide a variety of services to the grid by investing in distributed energy resources (DERs) such as distributed solar generation, programmable appliances, and energy storage. However, customers’ incentives to make these investments depend on how they are being charged for electric service. Despite the topic’s importance for the electric distribution system of the future, the body of literature on the impact of electric rate design on the proliferation of DERs is still limited. Our research improves upon common assumptions of fixed electric demand by incorporating microeconomic theory into an existing engineering simulation model.

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  • Reports

    Pipeline Approvals and Greenhouse Gas Emissions

    April 9, 2019

    In light of growing public awareness of the environmental effects of pipeline projects, the Federal Energy Regulatory Commission (FERC) has faced competing pressures regarding how to balance the need for new natural gas pipelines with their environmental consequences. Concerns about greenhouse gas (GHG) emissions and resulting climate change effects have become a flashpoint in the debate. Our report examines the legal context surrounding FERC’s evaluation of the environmental impacts of proposed interstate natural gas pipelines. We look at FERC’s obligations under the Natural Gas Act and the National Environmental Policy Act, as well as potential improvements the agency can make to its analyses to better inform policy makers and the public about the impacts of proposed projects.

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