Resources

  • Institue for Policy Integrity Comments to the California PUC on Energy Storage

    We recently submitted comments to the California Public Utilities Commission on the Self-Generation Incentive Program (SGIP). Retrospective review of SGIP has found that, contrary to the program’s goals, greenhouse gas emissions sometimes increase when energy storage systems are deployed. To address this unintended consequence, the CPUC Energy Division Staff issued a set of recommendations on how to improve the program, including by creating a real-time greenhouse gas emissions factor for energy storage operators to use, and by tying the SGIP incentive payments to greenhouse gas performance. Our comments provide the CPUC with our original analysis on energy storage to support these recommendations, including our recent report, Managing the Future of Energy Storage, and an academic article, by Policy Integrity’s Director, Richard Revesz, and Energy Policy Director, Burcin Unel, Ph.D, on energy storage and greenhouse gas emissions.

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  • Institute for Policy Integrity Comments to Virginia on Integrated Resource Planning

    We recently submitted comments to the Virginia State Corporation Commission on the integrated resource plan (IRP) of the Appalachian Power Company. These comments focus on how the Commission should require utilities to analyze climate impacts when planning how to balance future fossil fuel-based electricity generation against renewable energy options. Under the Virginia Code, the Commission is required to consider whether IRPs are “reasonable” and “in the public interest.” We make the case that climate damages fall squarely within the realm of public interest. Therefore, we argue that the Commission should require electric utilities to more transparently quantify the greenhouse gas emissions of alternatives, and to monetize the associated climate damages using the Social Cost of Greenhouse Gas metrics. Such analysis is necessary to allow the Commission to rationally identify the most efficient plan option that advances social welfare for Virginia, and to allow ratepayers and citizens to better understand the environmental effects of the portfolios chosen.

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  • Institute for Policy Integrity Comments on Vermont’s Standard Offer Program

    We recently submitted comments on Vermont’s standard offer program, which is designed to support smaller-scale renewable energy projects. One component of the standard offer program compensates generators that provide benefits to grid operation and management. In the past, the Vermont Public Utilities Commission has focused its view of these benefits to reward only generators that relieve transmission constraints. However, our comments urge the PUC to take a broader view of benefits to grid operation and include resilience benefits and avoiding climate effects on the grid. We cite our July 2018 report, Toward Resilience, to give the PUC more guidance on how to think about and value grid resilience. We also recommend that, when more broadly assessing the entire standard offer program’s benefits, the PUC should monetize any avoided climate externalities by using the social cost of greenhouse gases.

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  • Institute for Policy Integrity Comments to the Colorado Public Utilities Commission on Electric Resource Planning

    We recently submitted comments about to the Colorado Public Utilities Commission, which is reviewing its rules on electric resource planning (“ERP”). Our comments aim is to ensure that a proper valuation of externalities is integrated into Colorado’s ERP process, and we suggest using the Social Cost of Carbon to monetize greenhouse gas externalities.

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  • Institute for Policy Integrity Comments to the Nevada PUC on the Proposed Regulation to Implement SB 65

    The Nevada Public Utilities Commission recently released a proposed regulation to implement Senate Bill 65, which directs the PUC to give preference to those measures and sources of supply that provide the greatest economic and environmental benefit to the State. In our joint comments with Western Resource Advocates and Environmental Defense Fund, we express our support for these revisions to Nevada’s resource planning regulations. Specifically, we support the Commission’s application of the Interagency Working Group (IWG) Social Cost of Carbon (SCC) estimates to calculate the Present Worth of Societal Costs in Nevada, as reflected in the proposed regulation. In addition, we update the PUC on the use of the IWG SCC estimates in other states, including California, Colorado, Minnesota, New York and Washington State.

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  • How States Can Value Pollution Reductions from Distributed Energy Resources

    DERs are a growing part of the U.S. electric system and many state electric utility regulators are looking to more accurately compensate them by paying for a variety of the benefits that these resources provide. Most states are currently focusing on energy and distribution-level benefits, but this approach overlooks the environmental and public health impacts of DERs. Even though some states like California and New York have been working on analyses that include environmental attributes of DERs, few regulators have attempted a thorough evaluation of the environmental and public health benefits. Our report, Valuing Pollution Reduction, lays out a practical methodology for calculating the E value, the highlights of which are captured here. Specifically, this issue brief describes how to appropriately value environmental and public health benefits by monetizing the economic, health, and climate damages avoided emissions would have caused. State utility regulators can use the steps described here, weighing tradeoffs between accuracy and administrability, to implement their own program to holistically compensate DERs.

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  • Institute for Policy Integrity Comments to New York on Electricity Rate Design

    New York State is in the process of reforming its payment system for distributed energy resources (DERs), such as rooftop solar panels, away from a net energy metering policy that compensated these resources at retail electricity rates. Our comments to the New York Public Service Commission encourage the state to move towards rate designs that better reflect the underlying costs of generating, transmitting, and distributing electricity, including environmental externalities for all customers, including those who do not own DERs.

    Our joint comments with other stakeholders also offer high-level principles for rate design that can help achieve the state’s clean energy goals.

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  • Institute for Policy Integrity Comments on California’s Distributed Energy Resources Policy

    We submitted comments to the CPUC commending the agency for its revisions to the proposed analysis and recommending additional improvements. We encourage the CPUC to use the Societal Cost Test to not only gather information, but to use it as the primary tool to guide investment decisions. We also encourage the CPUC to follow its revised plan and our earlier recommendations by using the Social Cost of Carbon, as developed in 2016 by the federal government, to consider the climate benefits that DERs can provide by displacing fossil fuel generation. We also encourage CPUC to use methods developed by the US Environmental Protection Agency to calculate the air quality benefits that DERs can provide, while the state develops a more robust method. These actions will allow the Commission to make investments that provide the greatest net benefits.

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  • How the Trump Administration Is Obscuring the Costs of Climate Change

    When federal and state policymakers account for the impacts of climate change, they regularly use a tool called the Social Cost of Carbon (SCC). The SCC puts a dollar value on the most significant, quantifiable damages caused by each additional ton of carbon dioxide emitted. The most recent estimate of the cost is at least $51 per ton and rising over time. But now, turning its back on years of work, the Trump administration has disbanded the federal group that developed the SCC, and produced a new “interim” estimate claiming that each ton of carbon dioxide causes as little as $1 in climate damages. This issue brief describes how the Trump Administration reached this misleading number by ignoring the interconnected, global nature of our climate-vulnerable economy and obscuring the devastating effects that climate change will have on younger and future generations. Though the administration has been proposing rollbacks of environmental rules using this problematic SCC estimate as justification, we explain why federal agencies and state governments should continue using the most recent estimate by the Interagency Working Group that developed the SCC.

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  • Federal Lands and Fossil Fuels: Maximizing Social Welfare in Federal Energy Leasing

    This Article suggests a rational path forward for federal fossil fuel leasing. Just as a private company would seek to maximize net revenue in its operations, Interior should seek to manage its program to provide maximum net benefits to the public, to whom public resources belong. This includes accounting for all of the costs and benefits of leasing—including environmental and social costs—and adjusting the fiscal terms of its fossil fuel leases to recoup unmitigated externality costs. The Article describes how maximizing social welfare is consistent Interior’s statutory mandates, legislative history, judicial precedent, and principles of executive review that instruct agencies to maximize the net benefits of their policy choices. The reforms suggested here can significantly increase revenue for states and the federal government while reducing greenhouse gas emissions, illustrating the utility of using fiscal reform as a policy lever in the absence of comprehensive climate change legislation.

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