Comments

  • Institute for Policy Integrity Comments on California Electricity Policy

    California’s state government is moving forward on electricity and climate policy, likely setting a blueprint for future state and federal action. We submitted comments to the California Public Utilities Commission (CPUC) on factual disputes flagged by stakeholders, related to how utilities will use cost-benefit analysis in decisionmaking. We encouraged staff at CPUC to use the Social Cost of Carbon for its interim greenhouse gas adder, use a 3% discount rate for future damages, include other environmental externalities like air pollution in its analysis, and continue considering societal costs to ensure that the benefits justify the costs of a proposed policy.

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  • Institute for Policy Integrity Comments to the California Public Utilities Commission on an Interim Greenhouse Gas Adder

    The California Public Utilities Commission proposed using a Societal Cost Test to help select the combination of distributed energy resource projects that will result in the greatest net benefits to society. We counter the feedback that some stakeholders gave on implementing this approach in our reply comments. We argue that the Commission should: (1) expand its discussion of the legal basis for applying a societal cost test that includes a full range of externalities; (2) use the damage cost approach to determine the value of greenhouse gas abatement, rather than the proposed abatement cost approach; and (3) apply a societal discount rate to the analysis.

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

    We support California’s decision to use the societal cost test, and want to help ensure it reflects the best available analysis. We recommend that the CPUC use the societal cost test as its primary test whenever it evaluates DER programs, and that it use a low societal discount rate for this test. We also recommend that the PUC use the damage cost approach in determining the value of pollution abatement, and apply the social cost of carbon, which reflects the best available science and economics and has been developed through a transparent process. Finally, our comments recommend that the analysis include the full range of reasonably quantifiable externalities, rather than just including climate damages.

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  • Institute for Policy Integrity Comments on New York State Benefit Cost Analysis Handbooks

    We recently submitted reply comments to the New York State Public Service Commission on Benefit Cost Analysis Handbooks submitted to the Commission by utility companies, within the Reforming the Energy Vision proceeding. Benefit-cost analysis will assist in determining the best resource allocations between traditional utility distribution grid investments and distributed energy resources (DER), by allowing for direct comparison. These Handbooks will help ensure that the utilities’ benefit-cost analyses will help to select investment options that will maximize net benefits to the public.

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  • Institute for Policy Integrity Comments on New York State Zero-Emissions Attributes

    We recently submitted comments to the New York State Department of Public Service Staff regarding their Responsive Proposal for Preserving Zero-Emissions Attributes. This Proposal offers recommendations on how to achieve New York’s clean energy target: 50 percent of all electricity used in the state by 2030 should be generated by renewable energy sources.

    In valuing and compensating clean energy resources, it is important to have consistency across different types of resources. Our comments explain that while using the Social Cost of Carbon to value zero-emission attributes of energy resources is a correct approach, the Commission should be consistent in its valuations to avoid distortion of the relative value of different types of resources, which could lead to artificially low valuation of renewable energy sources.

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  • Institute for Policy Integrity Comments on the New York Clean Energy Standard - White Paper

    The 2015 New York State Energy Plan set one of the most ambitious clean energy targets in the nation: 50 percent of all electricity used in the state should be generated by renewable energy sources. The Department of Public Service Staff recently released a White Paper on the Clean Energy Standard, with recommendations on how to achieve this ambitious goal. We submitted comments to the New York State Public Service Commission, outlining some additional steps that can help ensure that the Clean Energy Standard is not excessively costly, and is effective in achieving all of its policy goals.

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  • Institute for Policy Integrity Comments on Net Metering and Distributed Energy Valuation in New York

    We recently submitted comments to the New York Public Service Commission on how the Commission should develop an interim successor to its net metering policy, and how distributed energy resources should be valued in the future. We filed the comments jointly with the Environmental Defense Fund. To begin to move the retail electricity markets toward efficient and accurate recognition of the value of distributed energy resources, we suggest that the Commission should enhance its existing net energy metering policy to align compensation with the system benefits provided by distributed energy resources; establish a fully unbundled retail price structure; and specifically account for the environmental benefits of distributed energy resources in future pricing structures.

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  • Institute for Policy Integrity Comments on New York State’s “Reforming the Energy Vision” Initiative

    We recently submitted comments to the New York State Public Service Commission regarding the Reforming the Energy Vision (REV) initiative, which seeks to spur clean energy innovation and improve consumer choice and affordability in New York State. The Commission sought comments on how best to develop a cost-benefit analysis framework to evaluate utility proposals within the REV and related proceedings. Our comments addressed the consideration of externalities and the social cost of carbon in the Commission’s cost-benefit analysis.

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  • Institute for Policy Integrity Comments on Net Metering in Wisconsin

    Policy Integrity submitted comments to the Public Service Commission of Wisconsin, arguing that both the positive and negative externalities of distributed solar generation should be considered when determining net metering rates. Specifically, we suggest that the Commission should: Adjust the proposed net metering rate to include the health and environmental benefits associated with the avoided greenhouse gas (GHG) emissions and emissions of local pollutants; Adjust the proposed net metering rate to include the value of the net impact of distributed solar generation on the local grid; and Consider regulatory reforms to better achieve Wisconsin’s energy goals.

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