Resources

  • Expert Report on Colorado’s Zero Emission Vehicle Program

    In July 2019, Peter Howard and Jason Schwartz provided an expert report on Colorado’s Zero Emission Vehicle program, which will reduce millions of tons of greenhouse gas emissions annually. They demonstrate how the program’s climate benefits can be monetized and how those estimates can provide useful context for decisionmakers and the public.

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  • Testimony to New Jersey Legislature on Valuing Climate Impacts

    Peter Howard and Denise Grab both provided testimony at an April 25 New Jersey State Legislature hearing on climate change mitigation and what the state can do to address greenhouse gas emissions. They discussed how New Jersey can contextualize and weigh climate impacts by using the social cost of greenhouse gases.

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  • Pipeline Approvals and Greenhouse Gas Emissions

    In light of growing public awareness of the environmental effects of pipeline projects, the Federal Energy Regulatory Commission (FERC) has faced competing pressures regarding how to balance the need for new natural gas pipelines with their environmental consequences. Concerns about greenhouse gas (GHG) emissions and resulting climate change effects have become a flashpoint in the debate. Our report examines the legal context surrounding FERC’s evaluation of the environmental impacts of proposed interstate natural gas pipelines. We look at FERC’s obligations under the Natural Gas Act and the National Environmental Policy Act, as well as potential improvements the agency can make to its analyses to better inform policy makers and the public about the impacts of proposed projects.

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  • Opportunities for Valuing Climate Impacts in U.S. States

    With an absence of federal leadership on climate change, many states have worked to reduce greenhouse gas emissions on their own, often by incorporating a broader range of considerations into electricity policy. This Institute for Policy Integrity report assesses the potential to expand the valuation of climate damages in state electricity policy using Social Cost of Carbon metrics. We examine existing statutes and regulations in all 50 states to identify opportunities for valuing climate impacts around the country.

    State electricity regulators have a significant opportunity to use economic approaches like valuing climate impacts to better inform their decisionmaking. This approach can be used to account for the impacts associated with different types of proposed generation resources. Regulators in 10 states have already begun the process of using monetary estimates of climate damages in their electricity proceedings. In these jurisdictions, climate damages are taken into account in three main ways: utility resource planning, compensation for low or zero-emissions resources, and cost-benefit analysis frameworks.

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  • Colorado Senate Testimony on the Social Cost of Carbon

    In 2019, Colorado is considering a major overhaul of its electric resource planning rules and renewable energy standards. Jason Schwartz provided testimony in a Senate hearing on the reauthorization of the state’s Public Utilities Commission as part of this overhaul. Schwartz spoke about a possible requirement for the PUC to weigh the social costs of pollution in its decisions. Coloradoans, he explained, are paying the costs of climate pollution in the form of more dangerous wildfires, agricultural damages, declining snowpack, and a range of severe health effects. Many of these important costs can be quantified. In his testimony, Schwartz recommended that the PUC uses Social Cost of Greenhouse Gases metrics when evaluating energy resources in order to improve public welfare.

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  • Institute for Policy Integrity Comments on New Jersey Rejoining the Regional Greenhouse Gas Initiative

    New Jersey is proposing a new state carbon emissions trading program, which means it will rejoin the Regional Greenhouse Gas Initiative (RGGI). RGGI is a cooperative effort among northeastern states to reduce carbon emissions from the electric power sector through allowance trading. New Jersey previously left the initiative in 2011. RGGI expansion promises several benefits, such as improved market efficiency, increased competitiveness, and lower carbon reduction costs. We submitted comments to both RGGI and New Jersey on how to best reintegrate the state.

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  • A Lower Bound: Why the Social Cost of Carbon Does Not Capture Critical Climate Damages

    The Social Cost of Carbon, developed by the Obama-era Interagency Working Group (IWG), is the best available tool for measuring the economic damages from greenhouse gas emissions. It has been used in analysis for over 100 federal regulations that affect greenhouse gas emissions, as well as by a number of states in electricity and climate policy. Still, many significant impacts identified by the Intergovernmental Panel on Climate Change are difficult to quantify and so have been omitted from the IWG SCC estimates. Impacts such as increased fire risk, slower economic growth, and large-scale migration are all unaccounted for, despite their potential to cause large economic losses. Our new issue brief discusses these omissions and other variables that will influence climate outcomes. We encourage policymakers to account for this likely underestimate by viewing the SCC as a lower bound for damages.

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  • Institute for Policy Integrity Comments to the California Air Resources Board on its Cap-And-Trade Program

    Our previous comments in October 2017 and March 2018 suggested that ARB set the allowance price ceiling at least as high as the Interagency Working Group’s Social Cost of Carbon (SCC) estimates. We now recommend that the price floor should also account for the SCC. Setting both parameters appropriately is crucial to ensuring that the program sends effective price signals and accurately reflects the damage caused by carbon emissions. Our comments also address the ARB’s discussion of leakage, offset projects located outside the U.S., and how California can better allocate unsold carbon allowances.

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  • Institute for Policy Integrity Comments on New Jersey’s Energy Master Plan

    New Jersey is revising its Energy Master Plan (EMP) for 2019. In advance of the first draft of the plan, the New Jersey Board of Public Utilities, along with other state agencies, formed a committee to engage with stakeholders on the contours of the new plan. We submitted comments to the EMP Committee with a number of recommendations. Specifically, in drafting the 2019 EMP, we advise the Committee to consider grid resilience in a holistic manner and apply cost-benefit analysis to resilience plans and investments; adopt a granular approach to rate design, rather than use net metering; and design an incentive structure for energy storage operators to ensure that the use of energy storage systems reduces greenhouse gas emissions. These recommendations draw upon several of our recent publications on electricity policy, including reports on grid resilience and energy storage, and an academic article, also on energy storage. The first draft of the EMP is scheduled to be released this winter.

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  • Expert Testimony on Colorado’s Low Emission Vehicle Program and the Social Cost of Carbon

    In 2018, Policy Integrity submitted expert testimony on the benefits of Colorado’s proposed Low Emission Vehicle Program. The LEV program could avoid millions of tons of greenhouse gas emissions, and we explain to the Colorado Air Quality Control Commission the importance of and methodology for monetizing the real-world contributions of those emissions to global climate change. Our report shows, by applying Social Cost of Carbon estimates, that Colorado’s proposed LEV program could generate billions of dollars’ worth of climate benefits.

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