• Comments to Rhode Island on Carbon Pricing Study

    Rhode Island is undertaking a study to understand what a state carbon pricing scheme would look like and how it would interact with the state’s participation in the Regional Greenhouse Gas Initiative and the Transportation and Climate Initiative. Policy Integrity submitted comments that support the exploration of implementing a multisectoral carbon price and recommend that the state study a scenario that uses the federal Interagency Working Group’s Social Cost of Carbon.

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  • Option Value and the Social Cost of Carbon: What Are We Waiting For?

    Scientists and economists have long recognized that significant uncertainties and irreversibility characterize climate change. And yet, the social cost of carbon (SCC), the preeminent policy tool to address climate change applied by the U.S. government, does not include the option value (OV) that arises due to these characteristics. We demonstrate a simple methodology for approximating the OV underlying the SCC using the Bachelier formula.

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  • Policy Integrity Comments to the Colorado Public Utilities Commission on Electricity Rule Changes

    The Colorado Public Utilities Commission is amending its rules relating to utilities, electric resource planning, and renewable energy standards. Policy Integrity submitted comments explaining why the Commission should use Social Cost of Greenhouse Gases estimates to monetize the externalities of carbon pollution. Our recommendations include rule revisions and new language that will help include monetized estimates of climate impacts in all relevant decisionmaking. Policy Integrity also submitted comments and reply comments on additional rule revisions, building on our original comments to further describe how the Commission can best express and apply the Social Cost of Greenhouse Gases.

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  • 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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