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Recent Projects

  • Comments to FERC in Support of Technical Conference on Capacity Accreditation

    Policy Integrity submitted comments to FERC in support of American Clean Power Association’s petition for a technical conference on capacity accreditation. Holding a technical conference would be appropriate because accurate accreditation is becoming increasingly difficult as grids accommodate rapidly changing resource mixes with varying energy and reliability attributes, public policy constraints, and increasing/unprecedented extreme weather events. Moreover, accreditation has become more consequential, as capacity market revenues have grown to a significant share of total market payments. We included several questions that would merit discussion at the technical conference.

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  • Comments to DOE on Coordination of Federal Authorizations for Electric Transmission Facilities

    The Department of Energy (DOE) issued a proposed rule under 16 U.S.C. § 824p(h) to expedite the federal authorization of transmission projects. We commented in support of the proposal, including DOE's proposed requirement that project proponents describe how the transmission project would affect power-system greenhouse gas (GHG) emissions. We recommended that DOE clarify that project proponents must also estimate changes to non-power-system GHG emissions (e.g., upstream emissions of natural gas) and power-system emissions of local air pollutants. We also suggested that DOE provide additional guidance on the meaning of terms like "disadvantaged communities" and "communities with environmental justice concerns." Finally, we argued that DOE should provide an opportunity for public comment at the pre-application stage of the process.

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  • Comments to CEQ on Proposed Revisions to NEPA Implementing Regulations

    In July, the Council on Environmental Quality proposed revisions to the implementing regulations under the National Environmental Policy Act. The Proposed Rule reflects a more holistic approach to informing agency decisions with a robust and balanced analysis of environmental impacts. In our comment letter, we suggested improvements to the proposal that would help ensure robust and balanced treatment of environmental impacts in NEPA reviews.

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  • The Social Cost of Carbon Cover

    The Social Cost of Carbon

    Options for Applying a Metric in Flux

    Many states and other jurisdictions are grappling with how to value greenhouse gas emission reductions and trying to understand the rapidly developing climate economics and science involved in this task. Frequently, state governments and other jurisdictions value greenhouse gas emissions in policymaking using a tool known as the social cost of carbon.

    While applying the social cost of carbon is conceptually simple, the appropriate value to place on the metric is in flux. In late 2022, the federal government released new, updated values of the social cost of carbon in draft form which, for now, remain unfinalized. So what estimates of the social cost of carbon should states and other entities use during this transition period? This policy brief explores the available options.

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  • Administrative Severability Cover

    Administrative Severability

    A Tool Federal Agencies Can Use to Address Legal Uncertainty

    Several recent developments in administrative law—namely the Supreme Court’s embrace of the major questions doctrine and decision to hear a case asking it to overrule or clarify Chevron deference—have left federal agencies uncertain about how regulations will fare in litigation. Agencies adapting to this uncertainty may want to pay closer attention to recent case law on administrative severability, which allows a court to sever the invalid portion of a rule while leaving the rest intact.

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  • Comments to NJBPU on the Development of Natural Gas Utility Emission Reduction Plans

    The New Jersey Board of Public Utilities is examining how to reduce greenhouse gas emissions from the state's natural gas sector in line with New Jersey's economy-wide emissions reduction goals. Policy Integrity submitted comments focused on the planning process and solutions needed to responsibly transition away from natural gas usage.

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  • Wildfire, Power Shutoff, and Residential Energy Storage Adoption Cover

    Wildfire, Power Shutoff, and Residential Energy Storage Adoption

    Extreme weather poses a growing threat to electrical grid stability. On-site battery storage connected to solar power —known as a solar-plus-storage system—can buffer the impact. Despite its crucial benefits, the widespread adoption of this technology is hindered by its high costs. This study examines the impact of recent salient events—namely, preemptive power shutoffs to prevent wildfires, or Public Safety Power Shutoffs (PSPSs)—on residential solar-plus-storage adoption. I demonstrate that while communities at risk of wildfires lacked proactive investments before wildfire seasons, prolonged PSPSs increased solar-plus-storage adoption during the subsequent two months. This increased storage uptake can be attributed to heightened awareness of the need for backup power. Additionally, households’ choices between purchasing and leasing options were influenced by latent wildfire hazards and education levels. These findings highlight the role of risk awareness in promoting storage adoption and underscore the potential for using public information to enhance wildfire preparedness.

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  • Comments to PJM on the Resource Adequacy Critical Issue Fast Path

    PJM Interconnection, which oversees wholesale electricity market operations for the mid-Atlantic region, is undergoing reforms to improve how the market values and prices generation capacity to ensure reliability. Policy Integrity submitted comments focused on PJM's proposed shift to a seasonal capacity market design and other proposed changes to reliability metrics.

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  • Comments on the Consideration of Climate Benefits in Proposed Rule to Limit Methane Leakage from Gas Pipelines

    In May, the Pipeline and Hazardous Materials Safety Administration released a draft regulation to prevent methane leaks from gas pipelines. The agency monetized the climate benefits of the regulation using the social cost of methane, finding that monetized benefits exceeded monetized costs by at least $340 million per year. In our comment letter, we support the agency for applying the social cost of greenhouse gases to estimate the climate benefits of the proposed rule. We also suggest that PHMSA apply additional analysis to each rule using draft updated climate-damage valuations that the Environmental Protection Agency released in November 2022.

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  • Comments to NYSPSC on Its 2040 Zero-Emissions Electricity Goal

    The New York State Public Service Commission recently issued an order seeking input on how to achieve the state's goal of a zero-emissions electricity system by 2040, as required by the Climate Leadership and Community Protection Act (CLCPA). Policy Integrity submitted comments focused on issues such as the relationship between the Commission’s 2040 zero-emissions goal and other elements of the CLCPA, the need for analytic frameworks that rely on best available science and economics, the circumstances under which hydrogen could qualify as a zero-emissions resource, and tracking benefits to disadvantaged communities.

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