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National Academy of Sciences Reviews Social Cost of Carbon
The National Academy of Sciences (NAS) is currently conducting a review of the methodologies used to calculate the Social Cost of Carbon (SCC). We submitted comments to NAS to help inform this process.
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Distributed Energy Compensation Comments for NARUC
As distributed energy resources (“DER”) are becoming increasingly common, the debate on how customers with such systems should be compensated is intensifying in many states. The National Association of Regulatory Utility Commissioners (NARUC) is creating a Distributed Energy Resources Compensation Manual to assist states with these policy decisions. We recently submitted comments to NARUC’s Staff Subcommittee on Rate Design regarding the most economically desirable approach to use for DER compensation.
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Understanding the Stay
Implications of the Supreme Court’s Stay of the Clean Power Plan
Since the Supreme Court stayed EPA’s Clean Power Plan, which regulates carbon dioxide emissions from existing fossil fuel-fired power plants, opponents of the plan have been making unfounded assertions about the consequences of the stay. This policy brief aims to clarify the stay’s implications for EPA’s implementation work and the plan’s future compliance deadlines.
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Handbook of Regulatory Impact Assessment
Jason Schwartz, legal director at the Institute for Policy Integrity, authored a chapter in the new Handbook of Regulatory Impact Assessment. Schwartz’s chapter explores the varied applications and approaches to cost-benefit analysis in the context of regulatory impact assessment.
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New York Clean Energy Standard - White Paper Comments
The 2015 New York State Energy Plan set one of the most ambitious clean energy targets in the nation: 50 percent of all electricity used in the state should be generated by renewable energy sources. The Department of Public Service Staff recently released a White Paper on the Clean Energy Standard, with recommendations on how to achieve this ambitious goal. We submitted comments to the New York State Public Service Commission, outlining some additional steps that can help ensure that the Clean Energy Standard is not excessively costly, and is effective in achieving all of its policy goals.
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Comments on BLM Rule to Control Fugitive Methane Emissions
We recently submitted two sets of public comments to the Bureau of Land Management (BLM) regarding a proposed rule to reduce waste of natural gas from venting, flaring, and leaks during oil and gas production on federal and Indian lands. BLM has proposed making natural gas lost through these processes subject to royalty payments.
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Comments on Net Metering and Distributed Energy Valuation in New York
We recently submitted comments to the New York Public Service Commission on how the Commission should develop an interim successor to its net metering policy, and how distributed energy resources should be valued in the future. We filed the comments jointly with the Environmental Defense Fund. To begin to move the retail electricity markets toward efficient and accurate recognition of the value of distributed energy resources, we suggest that the Commission should enhance its existing net energy metering policy to align compensation with the system benefits provided by distributed energy resources; establish a fully unbundled retail price structure; and specifically account for the environmental benefits of distributed energy resources in future pricing structures.
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Balancing on the Grid Edge
Regulating for Economic Efficiency in the Wake of FERC v. EPSA
This new article from senior attorney Denise Grab is featured in a special edition of the Harvard Environmental Law Journal that focuses on the Supreme Court’s FERC v. EPSA case.
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Comments on FDA Proposal to Restrict Artificial Tanning
We recently submitted comments in response to the Food and Drug Administration’s (FDA) proposed rule to restrict the use of sunlamps used for artificial tanning. We concluded that although the proposed rule takes a significant step in reducing the risks of artificial tanning, the FDA should strengthen the justification for this proposed rule.
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Brief for Clean Power Plan Litigation
We recently submitted an amicus brief in the litigation over the EPA’s Clean Power Plan, which regulates carbon dioxide emissions from the power sector. A group of coal companies and states is asking the U.S. Court of Appeals for the D.C. Circuit to strike down the rule, arguing that it represents an unprecedented expansion of the EPA’s regulatory authority. Our brief shows that, in fact, there are regulatory precedents for every aspect of the rule that petitioners claim is unprecedented. Our analysis of past EPA regulations and court rulings reveals that the Clean Power Plan is consistent with decades of Clean Air Act practice under administrations of both parties.