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  • Markets, Externalities, and the Federal Power Act: The Federal Energy Regulatory Commission's Authority to Price Carbon Emissions Cover

    Markets, Externalities, and the Federal Power Act: The Federal Energy Regulatory Commission’s Authority to Price Carbon Emissions

    Article revised for the Environmental Law Reporter

    This article, excerpted from Davis Noll and Unel’s article in the NYU Environmental Law Journal, provides a comprehensive economic framework to show that addressing the CO2 externality through a carbon price falls within FERC’s authority to ensure an efficient market.

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  • Comments to New Jersey on Cost Test Straw Proposal

    The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. We submitted comments encouraging BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. We also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal. 

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  • Comments to EPA on Proposal for Cost-Benefit Analysis and the Clean Air Act

    We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.

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  • Amicus Brief in D.C. Circuit on Tennessee Pipeline Extension

    If constructed, the Tennessee pipeline extension and related projects would be responsible for substantial greenhouse gas emissions. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to quantify the project’s emissions and monetize climate damages using Social Cost of Carbon estimates is arbitrary.

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  • Amicus Brief in Appeal of Conscience Protections Decision

    Three federal courts—in the Southern District of the New York, the Northern District of California, and the Eastern District of Washington—vacated the Department of Health and Human Services’ conscience protections rule, which would have reduced healthcare access for women and LGBT individuals. Recently, the Department of Health and Human Services appealed the SDNY ruling. We filed an amicus brief in the Court of Appeals for the Second Circuit further highlighting the fundamental flaws in HHS's cost-benefit analysis of the conscience protections rule.

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  • New Mexico PRC Adopts Plan to Replace San Juan Coal Plant with Renewables Portfolio

    In 2022, New Mexico’s largest utility company will retire the San Juan Generating Station, a coal-burning power plant that has operated since 1973. In light of the decision, the state’s Public Regulatory Commission (PRC) has adopted a plan to replace the plant’s power output with 100 percent renewable energy and battery storage. The plan is a significant victory for the community groups and environmental advocates that have pushed to expedite the clean energy transition, and our efforts helped pave the way for this decision.

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  • Comments to Virginia on Developing an Energy Storage Rule

    The Virginia State Corporation Commission asked for input in advance of developing a rule for energy storage deployment. Our comments note that energy storage deployment can increase emissions from the electricity sector, even if those deployments also facilitate the integration of variable renewable resources. We urge the Commission, under the Virginia Clean Economy Act, to adopt a rule ensuring that energy storage resources are deployed and operated in ways that reduce net emissions.  

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  • Federal Court Rules Against Flawed, Domestic-Only Consideration of Climate Costs

    The U.S. District Court for the Northern District of California vacated the Bureau of Land Management's repeal of an Obama-era rule that was designed to reduce wasteful venting of methane from natural gas operations on federal lands. The court ruled in part that it was arbitrary for the Trump Administration to have reduced the estimate of the social cost of methane from $1300 per ton down to just $176 per ton by excluding from consideration any climate effect occurring outside U.S. borders. Policy Integrity has worked for years to build the case against the so-called “domestic-only” estimate of climate costs.

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  • Amicus Briefs on Navigable Waters Protection Rule

    In April, the Environmental Protection Agency (EPA) and Army Corps of Engineers published the Navigable Waters Protection Rule, which considerably restricts the waters and wetlands that are federally protected under the Clean Water Act. We filed briefs in the Northern District of California and District of South Carolina focusing on the agencies’ economic analysis, which the agencies use to obscure the rule’s anticipated harms.

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  • Weakening Our Defenses Cover

    Weakening Our Defenses

    How the Trump Administration’s Deregulatory Push Has Exacerbated the Covid-19 Pandemic

    The failure of the federal government to adequately safeguard the health, environment, and economy of the United States with efficient regulatory protections is not a new phenomenon. For over three years now, the Trump administration has systematically delayed, undermined, and erased key regulations that protect our health, our environment, our workplaces, our living conditions, and our economy. The steady erosion of regulatory safeguards has severely compromised our baseline defenses against Covid-19.

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