Resources

  • The Social Cost of Carbon Initative

    Researchers in this initiative are leading a team of distinguished economists and scientists to improve the science behind estimates of the social cost of carbon—the means by which the US federal government, state governments, and foreign governments account for climate change in their actions—through a process that ensures the highest levels of scientific quality and transparency and builds the scientific foundation for future estimates.

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  • Joint Comments to EPA on Climate Effects from Cross-State Air Pollution Rule

    In its proposal, Revised Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS, the Environmental Protection Agency’s (EPA) unreasonably low valuation of climate effects contributes to its selection of an inefficient policy alternative. Policy Integrity submitted joint comments detailing how EPA’s flawed analysis harms public health and the environment.

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  • Policy Integrity Comments to New York on the Value of Carbon

    New York’s landmark climate bill, the Climate Leadership and Community Protection Act, requires the New York State Department of Conservation (DEC) to adopt a value of carbon. In October 2020, DEC published draft guidance for New York State agencies on what value of carbon to use, focusing on the IWG’s 2016 Social Cost of Carbon estimates. Policy Integrity submitted comments supporting DEC’s decision to use a damage-cost approach and demonstrating why a 2% discount rate is an appropriate central discount rate for New York’s value of carbon estimates. Policy Integrity’s comments also address how DEC should address co-benefits, unquantified benefits, and distribution effects of policies and programs with greenhouse gas effects. Finally, the comments discuss several considerations and guiding questions for DEC if it chooses to move forward with a marginal abatement cost approach.

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  • Joint Comments to EPA on Airplane GHG Emissions Regulations

    The Environmental Protection Agency (EPA) proposed airplane pollution standards that have no effect on emissions and require no technological improvements. EPA does analyze one scenario in the technical support for the proposal, however, that appears to have modest greenhouse gas emissions reduction effects. But the agency improperly monetizes and weighs those reductions. Policy Integrity submitted joint comments that detail flaws in EPA’s analysis and describe how the agency can correctly apply the social cost of carbon.

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  • Policy Integrity Comments to Arizona on Integrated Resource Planning

    The Arizona Corporation Commission regularly requires that load serving entities (LSEs), which supply electricity to ratepayers, file plans with a 15-year time horizon disclosing environmental impacts from different resource mixes and how they will address those impacts. Policy Integrity’s comments encourage the Commission to ask that LSEs provide monetized estimates of the damages they expect to result from greenhouse gas emissions using the social cost of carbon.

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  • Making the Most of Distributed Energy Resources: Subregional Estimates of the Environmental Value of Distributed Energy Resources in the United States

    Distributed Energy Resources (DERs), like rooftop solar and battery storage, have the potential to generate significant social benefits by displacing pollution-emitting electricity generators. Accurately compensating DERs for this environmental and public health value, which some regulators and experts call the “E-Value,” is imperative for making the most out of DERs’ potential.

    This report provides a new set of hourly E-Values for the whole United States, broken down into 19 subregions, using an open-source reduced-order dispatch model. The patterns uncovered by these estimates can help policymakers design economically efficient DER policies to reduce air pollution from electricity generators.

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  • Policy Integrity 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. Policy Integrity’s comments encourage BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. The comments 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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  • Wisdom of the Experts: Using Survey Responses to Address Positive and Normative Uncertainties in Climate-Economic Models

    The social cost of carbon (SCC) and the climate-economic models underlying this prominent US climate policy instrument are heavily affected by modeler opinion and therefore may not reflect the views of most climate economists. To test whether differences exist, we recalibrate key uncertain model parameters using formal expert elicitation: a multi-question online survey of individuals who have published scholarship on the economics of climate change.

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  • Policy Integrity Comments to Oregon PUC on the Social Cost of Carbon

    Oregon Governor Kate Brown signed an executive order directing state agencies, including the Public Utilities Commission (PUC), to reduce greenhouse gas emissions. Policy Integrity submitted comments encouraging the PUC to use Social Cost of Carbon metrics to monetize the benefits of avoided greenhouse gas emissions.

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  • SOCIAL COST OF CARBON: Identifying a Federal Entity to Address the National Academies’ Recommendations Could Strengthen Regulatory Analysis

    This report examines, among other objectives: (1) how the federal government’s current estimates of the social cost of carbon compare to its prior estimates and (2) how the federal government plans to address the recommendations of the National Academies. GAO reviewed executive orders, OMB guidance, and regulatory impact analyses and interviewed OMB, EPA, NHTSA, and BLM officials and staff who had conducted such analyses. GAO recommends that OMB identify a federal entity responsible for addressing the National Academies’ recommendations.

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