Comments

  • 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 In October 2020, DEC published draft guidance for New York State agencies on what value of carbon to use, focusing on the IWG’s 2016 Social Cost of Carbon estimates.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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  • 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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  • 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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  • 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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  • 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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  • 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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  • 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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