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  • The Obligation to Serve in Massachusetts Cover

    The Obligation to Serve in Massachusetts

    Gas Service and the Energy Transition

    In Massachusetts, achieving the state’s decarbonization target in a cost-effective manner will likely require the refusal of new gas service in addition to the termination of existing gas service in certain buildings and its replacement with electric service. The scope of utilities’ legal obligation to serve their customers will be central to those efforts. This brief analyzes the contours of this obligation by examining the relevant Massachusetts statutes, regulations, Public Utility Commission decisions, and case law.

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  • Electricity Tariff Design via Lens of Energy Justice Cover

    Electricity Tariff Design via Lens of Energy Justice

    Distributed Energy Resources (DERs) can significantly affect the net social benefit in power systems, raising concerns pertaining to distributional justice and equity. Current tariff design approaches suffer from opaque efficiency-equity trade-offs and are also agnostic of the externalities that affect both economic efficiency and equity. Therefore, this paper develops a justice-cognizant tariff design framework that improves the operational savings in the system without sacrificing distributional equity, and encompasses economic welfare, social costs of environmental and public health impacts, and socio-economic and demographic characteristics of electricity consumers. We evaluate four different tariff structures using a Multi-Objective Problem with Equilibrium Constraints. We then compare the operational savings and equity of the proposed framework using the 11-zone New York ISO and 7-bus Manhattan power networks. The results demonstrate that justice-cognizant, and spatially- and temporally-granular tariffs ensure equity and increase the operational savings at a lower energy burden to consumers.

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  • Just Regulation: Improving Distributional Analysis in Agency Rulemaking Cover

    Just Regulation: Improving Distributional Analysis in Agency Rulemaking

    Forthcoming in Ecology Law Quarterly

    This Article seeks to understand the shortcomings of current agency practice and outline what agencies can do better. To do so, it examines fifteen significant proposed or final agency rules promulgated during the Biden-Harris Administration’s first eighteen months and reveals four categories of limitations. First, agencies often pursue inconsistent goals across different regulatory initiatives. Second, they do not grapple with the core issue that distributional analysis should raise: the extent to which the better distributional consequences of one alternative should trump the higher net benefits of another alternative. Third, agencies do not apply a consistent approach to defining disadvantaged groups, which makes the analysis inconsistent and unpredictable. Fourth, the distributional analysis relies on a truncated set of costs and benefits, and thus presents an incomplete picture of the consequences of regulation on disadvantaged communities.

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  • Best Practices for Energy Substitution Analysis Cover

    Best Practices for Energy Substitution Analysis

    In recent years, numerous federal agencies have made a controversial claim: that projects locking in fossil fuels over the long term will decrease aggregate greenhouse gas emissions, or that their effects on total emissions will be limited. In many of those cases, however, agencies have reached this counter-intuitive conclusion using a flawed consideration of energy substitution. This report identifies some of the recurring problems with agency analysis of energy substitution and offers best practices to apply moving forward.

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  • Still Your Grandfather‘s Boiler: Estimating the Effects of the Clean Air Act‘s Grandfathering Provisions

    Working paper

    While vintage differentiation is a highly prominent feature of various regulations, it can induce significant biases. We study these biases in the context of New Source Review—a program within the US Clean Air Act imposing costly sulfur dioxide (SO2) abatement requirements on new boilers but not existing ones. In particular, we empirically investigate how the differential treatment of coal boilers shaped the generation landscape by affecting unit utilization, retirement, and emissions. Focusing solely on the additional SO2 emissions, we estimate annual costs of up to $65 billion associated with the vintage differentiation in New Source Review.

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  • Unheralded and Transformative: The Test for Major Questions After West Virginia Cover

    Unheralded and Transformative: The Test for Major Questions After West Virginia

    Published in William and Mary Environmental Law and Policy Review

    In West Virginia v. EPA, the Supreme Court expressly relied on the “major questions doctrine” for the first time in a majority opinion to hold that a federal agency lacked authority to issue a regulation. Published in the William and Mary Environmental Law and Policy Reviewthis paper explores whether West Virginia provides such a framework and concludes that it does. A close look at West Virginia and the alternative frameworks that parties and others urged on the Court in the West Virginia litigation also reveals a great deal about what the major questions doctrine is not.

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  • Regulatory Antecedents and the Major Questions Doctrine Cover

    Regulatory Antecedents and the Major Questions Doctrine

    Working paper

    In recent years, federal courts have increasingly assessed the legality of regulatory action by considering its antecedents, or lack thereof, in prior agency actions. Yet as this article explains, federal agencies have insufficiently adapted to this increased judicial focus on regulatory antecedents. While significant agency rulemakings typically include extensive dockets with many different types of analysis, they have generally provided limited analysis of regulatory antecedents. This article suggests that agencies more extensively catalog regulatory antecedents at all stages of the rulemaking process, from drafting to promulgation.

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  • Advancing Energy Justice Conference Brief Cover

    Advancing Energy Justice Conference Brief

    Tools for Justice40 and Equitable Deep Decarbonization

    This brief summarizes some of the major points of discussion from our May 2022 conference, “Advancing Energy Justice: Tools for Justice40 and Equitable Deep Decarbonization.” The event brought together federal agency staff working to implement Justice40 with researchers to discuss how academic research can be more responsive to communities’ needs. This brief summarizes the varied views expressed by conference participants and is not intended to be a consensus or recommendation document.

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  • Enacting the  “Polluter Pays” Principle Cover

    Enacting the “Polluter Pays” Principle

    New York’s Climate Change Superfund Act and Its Impact on Gasoline Prices

    This policy brief analyzes how New York State’s recently proposed Climate Change Superfund Act is most likely to affect consumer gasoline prices. The Act would require payments from fossil-fuel companies based on their historical contributions to current greenhouse gas levels in the atmosphere. The payments would be used to build green infrastructure to help the state adapt to climate change. The brief finds that the Act would likely have a negligible impact on current and near-term oil prices, while potentially lowering future energy prices in New York, including for transportation.

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  • Do Non-Damaging Earthquakes Shake Mortgage Lenders' Risk Perception? Cover

    Do Non-Damaging Earthquakes Shake Mortgage Lenders’ Risk Perception?

    Working paper in Journal of Environmental Economics and Management

    This study examines how banks respond to earthquakes that convey seismic risk salience but do not cause damage, i.e., noticeable non-damaging earthquakes (NNDEs). Using evidence from California, we find loans more likely to be denied or sold after increased NNDEs. Banks with fewer assets, more diversified branching markets, or stronger sales capability relied more on securitization to transfer the perceived seismic risk. We show evidence that banks likely learned about the NNDEs through personal experience and local news. The effects of NNDEs persisted up to three years. Meanwhile, the NNDEs only caused moderate and temporary collateral devaluation but did not increase the observable default risk. Thus, banks' responses most likely resulted from the increased risk salience of future damaging earthquakes during the mortgage term. Our findings call for reevaluations of the heuristics in banks' risk-perception updating and have implications for designing more efficient disaster risk-sharing mechanisms in the financial market.

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