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ReportNo Turning Back
An Analysis of EPA’s Authority to Withdraw California’s Preemption Waiver Under Section 209 of the Clean Air Act
For 50 years, California has enjoyed unique authority to regulate air pollution from newly manufactured motor vehicles. While the Clean Air Act preempts all other states from setting their own vehicle emission standards, California can request a waiver to do so if it determines that its standards are at least as protective of public health and welfare as federal standards issued by the U.S. Environmental Protection Agency (“EPA”). Once a waiver is granted, other states can adopt California’s more stringent vehicle emissions standards as their own. EPA has now proposed to withdraw the waiver California received in 2013 to set its own greenhouse gas emission standards. Because a waiver withdrawal would be entirely unprecedented, neither courts nor legal scholars have previously had cause to discuss the circumstances, if any, under which a waiver might permissibly be withdrawn. This report analyzes whether EPA possesses revocation authority and, assuming it exists at all, when and how such authority may be exercised.
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ReportToward Resilience
Defining, Measuring, and Monetizing Resilience in the Electricity System
Grid resilience—generally, the electric grid’s ability to resist/absorb, manage, quickly respond, and recover from/adapt to high-impact, low-probability external shocks—has been a concern for electric utilities and energy planners for decades. While recent extreme weather and cyber security concerns have prompted the federal government to pursue policies that support coal and nuclear power plants, a more systematic focus on resilience will lead to very different solutions than what has been proposed by the Department of Energy. Our report aims to assist policymakers in understanding grid resilience and evaluating potential interventions aimed at improving grid resilience.
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ReportCapacity Markets and Externalities
Avoiding Unnecessary and Problematic Reforms
Many states are taking action on climate change by paying zero- and low-emitting electricity generators for avoiding the emissions that fossil-fuel-fired resources would otherwise emit. These “externality payments” help level the playing field between emitting and non-emitting generators. Critics of these policies argue that these payments might negatively affect the efficiency of wholesale electricity markets by reducing capacity prices, which heavily affect how generators enter and exit the market. Our report shows why the premises underlying recent reforms, which seek to shield capacity markets from the potential price impact of pollution externality payments, are flawed.
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ReportManaging the Future of Energy Storage
Implications for Greenhouse Gas Emissions
Many policymakers assume that increasing deployment of energy storage will automatically reduce greenhouse gas emissions, in part by helping to integrate renewable energy resources with intermittent and variable generation. This report, published in the Harvard Environmental Law Review, explores situations in which energy storage systems can in fact lead to increased emissions, and offers reforms to correct for poor incentives while ensuring that energy storage can provide the maximum benefit possible to the grid.
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ReportValuing Pollution Reductions
How to Monetize Greenhouse Gas and Local Air Pollutant Reductions from Distributed Energy Resources
Distributed energy resources (DERs)—grid-connected, small-scale electric generators such as rooftop solar installations, micro-turbines, combined heat and power systems, customer backup generators, and distributed energy storage systems—are a growing part of the U.S. electric system. They can help avoid the high levels of greenhouse gases and local air pollution produced by traditional energy sources. As their use grows, state electric utility regulators are seeking to compensate DERs accurately for the benefits they offer, including reductions in pollution that contributes to climate change and harms human health. This report shows how regulators can calculate the types and amount of pollution avoided, and then monetize these benefits for use in policy.
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