Recent Projects

In 2012, EPA issued the Mercury and Air Toxics Standards (MATS), which limit coal- and oil-fired power plants’ emissions of mercury and other hazardous air pollutants. In their most recent challenge to the rule, Petitioners seek to obscure the fact that regulating power plants’ emissions of hazardous air pollutants overwhelmingly benefits society by asking the U.S. Court of Appeals for the D.C. Circuit to ignore or discount large portions of EPA’s analysis—namely, its consideration of indirect benefits (sometimes called ancillary benefits or co-benefits) and unquantified benefits. But, as our amicus brief points out, EPA’s consideration of indirect benefits and unquantified direct benefits is consistent with the Clean Air Act, past court decisions, federal cost-benefit guidelines, economic best practices, and regulatory precedent. Overall, we argue that the agency’s cost-benefit analysis was properly conducted and more than satisfies its obligation to consider costs when determining whether regulation of power plants’ hazardous emissions is “appropriate and necessary.”

The EPA’s Carbon Pollution Standards for New Power Plants limit carbon dioxide emissions from new, modified, and reconstructed plants. A group of state attorneys general and energy companies have filed suit challenging the standards on several grounds. Policy Integrity submitted an amicus brief in support of EPA.

This summer, California extended its greenhouse gas emissions reduction program to 2030 with two companion bills. The legislation modifies how the Air Resources Board (ARB), the state agency responsible for regulating air pollution, should assess proposed policy measures and prioritize goals in designing regulations. ARB staff released a preliminary draft of the scoping plan for how to meet the new 2030 targets in early December and is expected to release a second draft for comment in mid-January. We submitted comments on the December draft, making recommendations on how to structure the scoping plan’s economic analysis to best achieve the goals laid out in ARB’s new mandate.

The New York State Public Service Commission’s “Reforming the Energy Vision” initiative, an effort to modernize New York’s electricity policy, seeks to integrate distributed energy resources (DERs) into the state’s energy supply. The Commission sought proposals on how to compensate these producers of electricity for the full value that they provide to the electric grid. We submitted joint comments with the Environmental Defense Fund on an appropriate valuation methodology. We encourage the Commission to include the full range of environmental benefits of DER, such as reduced air pollution, and to ensure consistency across the Commission’s other programs and across all technologies. This work builds on our earlier comments on unbundling price signals to compensate DER for the time-based, locational, and environmental benefits they provide.

In a proposed set of energy efficiency standards for refrigeration systems and residential furnaces, the Department of Energy (DOE) used the Social Cost of Carbon (SCC) to value the climate benefits of more efficient technologies. DOE did not, however, incorporate this benefit for other greenhouse gases such as methane. We recently submitted joint comments with the Environmental Defense Fund, Natural Resources Defense Council, and Union of Concerned Scientists to reaffirm the use of the SCC. We also encourage the agency to monetize the benefits of other greenhouse gas reductions, such as through the existing Social Cost of Methane methodology; and to continue to update these estimates to reflect the latest science and economics on the costs of climate change damages.

We recently submitted comments to the Environmental Protection Agency on the Clean Energy Incentive Program (“CEIP”). The CEIP is a voluntary early action program to help states move forward on Clean Power Plan compliance and energy market planning. Clean Power Plan opponents have argued that it is inappropriate for EPA to move forward on its CEIP guidance because the Supreme Court has stayed the Clean Power Plan.

We recently submitted comments to the New York State Public Service Commission, responding to petitions for rehearing on the Clean Energy Standard. The Commission’s Clean Energy Standard created Zero-Emissions Credits for nuclear generation, compensating these zero-emissions generators through a valuation system based on the Social Cost of Carbon (“SCC”). Various parties submitted petitions for rehearing or clarification, and criticized the Order on a variety of grounds. Among other criticisms, challengers argue that it was inappropriate for the Commission to use the SCC to value the zero‐emission attributes of nuclear energy resources alone, and that other types of low‐ emitting resources (e.g., small hydro) should receive commensurate payments for their zero‐emission characteristics.