We recently submitted comments to the Virginia State Corporation Commission on the integrated resource plan (IRP) of the Appalachian Power Company. These comments focus on how the Commission should require utilities to analyze climate impacts when planning how to balance future fossil fuel-based electricity generation against renewable energy options. Under the Virginia Code, the Commission is required to consider whether IRPs are “reasonable” and “in the public interest.” We make the case that climate damages fall squarely within the realm of public interest. Therefore, we argue that the Commission should require electric utilities to more transparently quantify the greenhouse gas emissions of alternatives, and to monetize the associated climate damages using the Social Cost of Greenhouse Gas metrics. Such analysis is necessary to allow the Commission to rationally identify the most efficient plan option that advances social welfare for Virginia, and to allow ratepayers and citizens to better understand the environmental effects of the portfolios chosen.
Related Reading
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Comments to CEQ on Carbon Capture, Utilization, and Sequestration Guidance
Project Updates / April 18, 2022
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Amicus Brief on New Jersey’s Zero-Emissions Credits Program
Project Updates / February 28, 2022
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Statement on SCOTUS Case on EPA Greenhouse Gas Regulation
Media Resources / February 28, 2022
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Louisiana Climate Lawsuit Is Parade of Damaging Mischaracterizations
In the News / December 21, 2021 / Bloomberg Law (Insight)
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Costs, Confusion, and Climate Change: Yale Journal on Regulation
Publications / December 14, 2021