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Recent Projects

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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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  • Reports

    Opportunities for Valuing Climate Impacts in U.S. State Electricity Policy

    April 2, 2019

    With an absence of federal leadership on climate change, many states have worked to reduce greenhouse gas emissions on their own, often by incorporating a broader range of considerations into electricity policy. Our report assesses the potential to expand the valuation of climate damages in state electricity policy using Social Cost of Carbon metrics. We examine existing statutes and regulations in all 50 states to identify opportunities for valuing climate impacts around the country.

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  • Academic Articles/Working Papers

    Regulation in Transition

    March 6, 2019

    This article, published in the Minnesota Law Review, identifies a new trend in aggressive regulatory rollbacks and argues that it is likely to become an enduring feature of American politics. Rather than stick to the typical deregulatory playbook, President Trump has made aggressive use of other instruments that had not previously played a significant role. Through these strategies, the Trump administration was able to reach a far greater proportion of regulations finalized during Obama’s presidency than would have been possible under prior practices. In the current climate, aggressive rollback strategies will lead to an important reconceptualization of the Executive Branch, in which future one-term presidents are unlikely to see a significant portion of their regulatory output on important matters survive and the incentives that presidents face in fashioning their regulatory policies will be significantly different. The changing incentives will affect a broad set of decisions, from transition planning for an incoming administration to the timing of regulatory actions relative to a president’s reelection campaign.

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  • Academic Articles/Working Papers

    Sociopolitical Feedbacks and Climate Change

    March 6, 2019

    This article, published in the Harvard Environmental Law Review, investigates sociopolitical feedbacks in the economy-climate system. These feedbacks occur when climate change affects the social or political processes that determine mitigation or adaptation levels, which in turn affect future climate damages. Two possible feedbacks are an economic disruption pathway and a political disruption pathway. In both, climate damages earlier in time undermine mitigation and adaptation policies, which exacerbates future climate damages. Using data on participation in multilateral environmental agreements, the article explores the political disruption pathway.

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  • Academic Articles/Working Papers

    Markets, Externalities, and the Federal Power Act

    February 22, 2019

    This article, published in the New York University Environmental Law Journal, shows how the Federal Energy Regulatory Commission (FERC) must attempt to address the external cost of carbon dioxide (CO2) emissions to achieve an efficient electricity market. CO2 emissions impose a significant cost on society by contributing to climate change. The electricity sector is a major source of these emissions, yet their external cost is not fully reflected in electricity rates, and the market outcomes thus do not adjust to reflect those true costs—a classic market failure. This leads to emissions that are higher than optimal.

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  • Academic Articles/Working Papers

    Environmental Standards, Thresholds, and the Next Battleground of Climate Change Regulations

    February 15, 2019

    This article, published in the Minnesota Law Review, addresses a central battleground of the debate about the future of greenhouse gas regulations: the valuation of particulate matter reductions that accompany reductions in carbon dioxide emissions. The benefits from particulate matter reductions are substantial for climate change rules, accounting for almost one half of the quantified benefits of the Obama Administration’s Clean Power Plan. These benefits are also significant for regulations of other air pollutants, making this issue one of far-reaching importance for the future of environmental protection.

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