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Our Work on State Zero-Emission Credits Programs

Several states have determined that ensuring the viability of zero-emission electricity generation from nuclear power is critical to mitigating the impacts of climate change especially in the short term while states work to meet aggressive new clean energy goals. Through comments and amicus briefs, we’ve been involved in those efforts in both New York and New Jersey.

In 2015, New York proposed a Zero-Emission Credits (ZECs) program. Our comments on the initial proposal encouraged the state to use the Interagency Work Group’s Social Cost of Carbon estimate to price the payments, which is the best available tool for valuing the avoided emissions of the program. After the state was sued, our 2017 and 2018 amicus briefs helped convince the courts of the rationality of New York’s program. The New York state court specifically rejected the challenge, citing our brief and the evidence we presented showing that the Social Cost of Carbon is the “best tool to reflect the environmental monetary damages attributable to reduced carbon emissions.”

New Jersey also recently passed a statute providing for Zero-Emission Credits. In a challenge to New Jersey’s program, we filed a brief explaining that using the SCC is the best way to account for benefits of avoided emissions both inside and outside New Jersey. A decision in that case is pending.