• 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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  • 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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  • Testimony on Retirement of the San Juan Coal-Fired Power Plant

    Jason Schwartz and Denise Grab prepared a testimony for the New Mexico Public Regulation Commission regarding a proposal to retire the San Juan Generating Units, a coal-fired power plant in New Mexico. Their testimony details how applying Social Cost of Carbon metrics would allow the Commission to better monetize and contextualize the climate impacts of the proposal. Retiring the San Juan coal units would deliver billions of dollars in benefits to agricultural productivity, property values, and human health.

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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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