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Glendale Water & Power RFP Seeks Distributed Energy, Capacity Resources

June 7, 2022

by Paul Ciampoli
APPA News Director
June 7, 2022

California public power utility Glendale Water & Power (GWP) has issued a request for proposals (RFP) that seeks proposals from contractors to develop and deliver distributed energy and capacity resources within the City of Glendale.

GWP is seeking up to 50 megawatts (MW) of reliable and dispatchable power capable of being incorporated into the city’s integrated resource portfolio. This capacity would be in addition to GWP’s existing local energy efficiency, demand response, and solar-storage hybrid programs.

This RFP implements the City Council’s direction to GWP to seek proposals for an additional 50 MW of distributed resources for the City’s energy portfolio while moving forward with planning for the replacement of the aging equipment at the City’s Grayson Power Plant.

The RFP seeks proposals in seven categories that would be connected to GWP’s distribution system or at a customer location(s):

1. Commercial and Industrial Solar Paired with Dispatchable Energy Storage

2. Residential Solar Paired with Dispatchable Energy Storage

3. Dispatchable Energy Storage to Pair with Existing Residential, Commercial and Industrial PV Solar Customers

4. Renewable Distributed Generation (DG)

5. Demand Response

6. Energy Efficiency

7. Any other clean DER solution not encompassed in the above categories

Responses to the RFP are due on September 30, 2022.

The RFP can be viewed at: https://www.glendaleca.gov/Home/Components/RFP/RFP/3082/2961

Biden Administration Moves to Boost Solar Manufacturing Capacity

June 7, 2022

by Paul Ciampoli
APPA News Director
June 7, 2022

The Biden Administration on June 6 said it would authorize the use of the Defense Production Act and leverage federal procurement to boost domestic solar energy technology production.

With respect to procurement, Biden directed the development of two tools:

According to a White House fact sheet, these federal procurement measures can stimulate demand for up to a gigawatt of domestically produced solar modules in the near term, and up to 10 gigawatts over the next decade from U.S. government demand alone.

To further increase the impact of these actions, the Biden Administration will also partner with state and local governments and municipal utilities in these innovative arrangements, increasing the potential market impact over the next decade to as much as over 100 gigawatts.

Defense Production Act

President Biden also authorized the Department of Energy to use the Defense Production Act to rapidly expand American manufacturing of five technologies:

24-Month Bridge For Solar Imports

President Biden also used his powers to create a 24-month bridge for certain solar imports, the fact sheet noted.

Specifically, the President is temporarily facilitating U.S. solar deployers’ ability to source solar modules and cells from Cambodia, Malaysia, Thailand, and Vietnam by providing that those components can be imported free of certain duties for 24 months.

This will ensure the U.S. has access to a sufficient supply of solar modules to meet electricity generation needs while domestic manufacturing scales up, the White House said.

California Renewable Energy Microgrid Comes Online

June 7, 2022

by Paul Ciampoli
APPA News Director
June 7, 2022

California’s first 100% renewable energy, front-of-the-meter, multi-customer microgrid is now fully operational. Located in Humboldt County, Calif., the microgrid provides energy resilience for a regional airport and U.S. Coast Guard Air Station.

This microgrid was developed through a first-of-its-kind partnership between the Schatz Energy Research Center at Cal Poly Humboldt, the Redwood Coast Energy Authority, Pacific Gas & Electric, the County of Humboldt, TRC, The Energy Authority, Tesla, Inc., and Schweitzer Engineering Labs.

Research and development was supported through a $5 million grant from California’s Electric Program Investment Charge (EPIC), a statewide program which invests in scientific and technological research to accelerate the transformation of the electricity sector to meet the state’s energy and climate goals, as well as by $6 million from the Redwood Coast Energy Authority, a joint powers agency that provides renewable energy to Humboldt County.

The Redwood Coast Airport Microgrid (RCAM) features a 2.2-megawatt solar photovoltaic array that is DC-coupled to a 2-megawatt (9 megawatt-hour) battery energy storage system, comprised of three Tesla Megapacks.

During standard blue-sky operations, RCAM generates renewable energy for the North Coast, and participates in the California Independent System Operator (CAISO) wholesale energy markets, including the day-ahead, real time, and ancillary services markets.

When a power outage occurs, the microgrid islands from the main grid and energizes the circuit that encompasses the airport, the adjacent Coast Guard Air Station, and several neighboring facilities. RCAM will provide seamless, ongoing electricity for all customers in the microgrid circuit during any local outages, Redwood Coast Energy Authority noted.

As the first microgrid in the CAISO market and the first renewable, front-of-the-meter microgrid system in the state, RCAM is building a replicable business model for renewable microgrid deployment, it added.

Additional details about the microgrid are available here.

Sandia Report Highlights Role Of Energy Storage In Energy Equity

June 6, 2022

by Peter Maloney
APPA News
June 6, 2022

Energy storage is a key component of legislation and policies being adopted by the federal government and many states, according to a new report from Sandia National Laboratories.

The report, Seeking Energy Equity Through Energy Storage, argues that energy equity is fundamental to “healthy and prosperous social and economic systems, and contributes to regional and national security and stability.” The authors also noted that energy equity is highlighted in the Biden administration’s Executive Order No. 13,985, Advancing Racial Equity and Support for Underserved Communities.

The authors of the Sandia report cite data showing that low-income households spend three-times more of their income on energy costs than more affluent households and that electricity prices have been rising at much steeper rates than other commodities.

“As a direct result of these factors, low-income households and underserved communities may be unable to afford such fundamental services as air conditioning or heating,” the Sandia report said.

Some 50 million households, or about 40% of total households, fall into the category of underserved populations that “incur an array of burdens from electricity generation that are unique to their communities,” such as pollution from nearby fossil fuel burning generation assets, more frequent outages, and lower access to technologies such as solar power and backup energy storage devices, the report said.

One solution has been community solar programs. Sixteen states have already adopted community solar programs intended to bring solar power and lower energy bills to disadvantaged communities. “Unfortunately, the vast majority of community solar subscribers have been businesses, universities, or other entities that have little trouble in paying the steep project enrollment fees for the program, while disadvantaged communities have yet to see any direct benefits,” the report said.

The report also noted that states such as New Jersey, Illinois, Colorado and New York have begun programs aimed at correcting the disparity and securing the flow of community solar benefits to disadvantaged communities.

Many states have also implemented programs to encourage the development of energy storage, including a number of state initiatives that have the potential to incorporate provisions related to serving disadvantaged communities, the report said, adding that those initiatives provide a blueprint for how energy equity policymaking may evolve. The report cited policies in California, Massachusetts, New Jersey, Virginia, and Illinois. The report’s authors also provided resources on how to measure equitable affordability and equitable resilience.

“If resilience, equity, environmental justice, and decarbonization are all to be prioritized together, energy storage and renewable energy will be at the heart of the technology solution,” the Sandia authors said. “To equitably provide resilience, some supply-side solutions must be sited close to vulnerable communities – providing critical services when the bulk power system fails,” they wrote. Those technologies, they said, must have very low-to-zero local pollutants and low-to-zero greenhouse gas emissions.

In conclusion, renewable energy, when coupled with energy storage, and grid-forming inverted technologies “are one of the only solutions ready today which can achieve these goals concurrently,” the report said.

California Community Choice Aggregator Lines Up Geothermal Energy Supplies

June 6, 2022

by Paul Ciampoli
APPA News Director
June 6, 2022

California community choice aggregator East Bay Community Energy (EBCE) has entered into its first geothermal power purchase agreement with Fervo Energy, a geothermal energy company.

Supplies will come from a project that will dispatch 40 megawatts of geothermal energy from Churchill County, Nevada to California’s regional grid, with expected operation in the fourth quarter of 2026. 

Serving Alameda County and fourteen incorporated cities, EBCE offers a power mix of carbon-free and renewable energy sources including wind, solar, hydro, and geothermal, with a goal of providing 100 percent clean electric service for its customers by 2030.

Group Says Ann Arbor, Mich., Municipalization Study RFP Falls Short

June 6, 2022

by Paul Ciampoli
APPA News Director
June 6, 2022

A group that supports municipalization efforts in Ann Arbor, Mich., recently said that a request for proposals (RFP) for a municipalization feasibility study falls short on several fronts.

In January, the Ann Arbor City Council took action to require the completion of a municipal electric utility feasibility study. In response, city staff recently issued an RFP.

In response to the RFP, Ann Arbor for Public Power (A2P2) noted that it supports a thorough and unbiased municipalization feasibility study. “However, this RFP is flawed, and could lead to a study that does not provide the information to accurately determine the technical and economic feasibility of an Ann Arbor municipal electric utility,” the group said.

“We are disappointed that the city rejected our requests to provide public comment prior to the release of this RFP, which could have prevented these flaws,” the group said.

To ensure the completion of a reliable feasibility study, it asked that an A2P2 representative be appointed to the proposal selection committee as an external collaborator, and that the proposal selection process be conducted with public transparency. The group wants its representative to be present at contractor interviews (if needed), at negotiations, and at selection committee meetings.

A2P2 said that the city must thoroughly evaluate both the potential costs and the potential benefits of municipalization to determine feasibility.

The group said that this task is typically performed in two steps. The first phase typically takes a modeling approach, based mainly on Federal Energy Regulatory Commission and state regulatory filings, presenting various scenarios to determine if a more rigorous follow up engineering-based study justifies the added expense, it said.

A2P2 noted that it advocated for an affordable preliminary feasibility study similar to those recently conducted by Pueblo, Colorado and Chicago, Illinois, each of which cost about $120,000.

“The scope of work of section 2 of this RFP is so extensive that we expect bids for this portion alone to come in many times higher.” The city has allocated $250,000 for the RFP, and the group believes that this funding amount will still be severely inadequate to fund the scope of work.

In addition, A2P2 said that the RFP requires exhaustive evaluations of the costs, concerns and risks of municipalization without a correspondingly complete assessment of its potential benefits.

The group quoted Ursula Schryver, American Public Power Association Vice President of Strategic Member Engagement & Education, as saying that overall, “it seems a bit biased negatively toward the municipalization option.”

She also noted that the RFP deliverables should have included estimates of municipal benefits, such as the potential value to the city of owning the distribution assets. These might include the ability to improve service reliability, to generate cash reserves, and the potential to improve overall city services by integrating the electric utility.

The group noted that more than 1,300 Ann Arbor residents signed petitions supporting a city-funded feasibility study, “and they deserve an efficiently conducted study that delivers a sound, unbiased answer. Tax dollars should be spent on a fiscally responsible and open feasibility study process, one that reliably evaluates the municipalization option.”

APPA Analysis Examines Regulated, Deregulated State Power Price Trends

June 6, 2022

by Paul Ciampoli
APPA News Director
June 6, 2022

Increases in retail electric prices from 1997 to 2021 were about half a cent more in states with deregulated electric markets than in regulated states, though regulated states had a slightly higher percentage increase in prices, according to an American Public Power Association (APPA) analysis of data from the U.S. Department of Energy’s Energy Information Administration.

APPA’s analysis also found that rates increased significantly in all states from 2020 to 2021, largely attributable to a rise in natural gas prices. Average total rates increased by six-tenths of a cent, or 5.7%.

Also, average rates in regulated states increased by 5.3% (from 9.5 cents to 10 cents), compared to a 6.7% increase in deregulated states (from 12 cents to 12.8 cents).

Since 2012, residential rates in deregulated states have increased by 2.5 cents, compared to a 1.4 cent increase in regulated states.

The report reviews data on electric rates in 16 states plus the District of Columbia — those with “retail choice” in place — compared to states that have traditional rate regulation.

The data show that after 24 years of deregulation, the original promise of reduced prices has not materialized, APPA said.

The full report is available here.

APPA’s Delia Patterson Joins Advisory Board Of E Source

June 1, 2022

by Paul Ciampoli
APPA News Director
June 1, 2022

Delia Patterson, Senior Vice President of Advocacy and Communications and General Counsel at the American Public Power Association (APPA), has joined the advisory board of E Source, the company announced on June 1.

“I’m thrilled to join the E Source advisory board and to contribute to furthering E Source’s mission,” said Patterson. “I look forward to connecting with my fellow advisory board members, the E Source team, and E Source clients to make significant progress on critical industry issues.”

“We’re extremely fortunate to have Delia join the E Source family,” said Ted Schultz, CEO of E Source. “Her insights and experience will help us deliver on E Source’s mission to build a sustainable future in partnership with utilities. She has spent her career helping utilities do the hard work they need to do and advocating for the interests of public power.”

E Source is a research, consulting and data science firm for the utility sector.

Patterson was recently elected president of the board of directors of the Energy Bar Association.

Patterson is also a member of the Department of Energy’s Electricity Advisory Committee, a member of the Lawrence Berkeley National Laboratory Future Electric Utility Regulation Advisory Group, and an associate member of the Commodity Futures Trading Commission Energy and Environmental Markets Advisory Committee. 

She is also on the board of the Women’s Energy Resource Council and is the member of APPA’s executive leadership team who leads energy policy formulation and advocacy before federal agencies, federal courts, and various energy policy forums.

FERC Votes To Permanently End Use Of MOPR In New England After Two-Year Transition

June 1, 2022

by Paul Ciampoli
APPA News Director
June 1, 2022

The Federal Energy Regulatory Commission (FERC) on May 27 voted to approve a proposal submitted by ISO New England (ISO-NE) under which the grid operator will eliminate a minimum offer price rule (MOPR) in its forward capacity market (FCM) and replace it with a reformed buyer-side market power mitigation construct.

ISO-NE Proposal And Background

In March, ISO-NE and the New England Power Pool Participants Committee (NEPOOL) jointly submitted proposed revisions to the ISO-NE Transmission, Markets and Services Tariff to modify the current MOPR in the FCM.

ISO-NE proposed to permit a specified quantity of “sponsored policy resources” to enter the market without being subject to buyer-side market power mitigation review during the next two forward capacity auctions (FCA) 17 and 18, and thereafter, beginning with FCA 19, eliminate the current MOPR and replace it with a reformed buyer-side market power mitigation construct.

As part of its FCM, ISO-NE holds an annual FCA in which capacity suppliers compete to provide capacity to the New England region for the relevant delivery year, three years in the future. Suppliers of capacity that receive a capacity supply obligation in an FCA commit to, and receive payment for, providing capacity for that one-year period associated with that FCA.

Currently, ISO-NE’s buyer-side market power mitigation rules utilize a MOPR that requires new capacity resources to offer their capacity at prices that are at or above a price floor set for each type of resource.  By imposing such a minimum offer price, the MOPR is intended to “mitigate” uncompetitively low bids, including resources that benefit from certain subsidies.

In its order, FERC notes that over the past decade, New England states have sought to reduce greenhouse gas emissions and meet climate goals through various mechanisms outside of the ISO-NE markets.

Those efforts have included legislation that allowed state-regulated utilities to enter into long-term contracts with certain defined resource types.

However, the MOPR does not allow resources receiving out-of-market revenues to account for that support in their offer prices, unless the support is widely available to other market participants.

As noted by ISO-NE in its filing, new resources supported through state legislation carry an elevated risk that their subsidized offers will be mitigated, making it more likely that they will fail to clear in the FCA.

ISO-NE acknowledges that, because capacity obligations generally must be met through resources that have cleared the FCA, exclusion of state-sponsored resources from the FCM forces consumers to effectively pay for capacity twice — once to meet the resource adequacy objectives of the FCM and a second time to meet the policy objectives of the states.

ISO-NE said that its MOPR reforms are necessary to facilitate entry into the FCM of substantial amounts of capacity from state-sponsored resources over the next several decades, avoiding the potential for an inefficient overbuild of the region’s capacity. 

ISO-NE explained that New England states have undertaken significant clean energy and decarbonization initiatives over the last five years such that the existing market rules designed to accommodate the participation of state-sponsored resources within the FCM are unlikely to sufficiently address the potential for excess capacity procurement throughout the region.

Accordingly, ISO-NE proposed to implement certain MOPR reforms to replace the existing rules for state-sponsored resources, following a two-year transition period.

The grid operator proposed a transition mechanism for FCAs 17-18 to permit a defined quantity of state-sponsored resources unmitigated entry into the FCA in a measured fashion to protect reliability, investors, and consumers.

ISO-NE proposed a graduated replacement of the MOPR for two central reasons: (1) concerns about adverse impacts to reliability from inefficient retirements and from likely delays in the development of state-sponsored resources, and (2) the need to provide the region time to undertake market reforms to facilitate the reliable transition to the new resource mix.

Details On FERC Order

In its order, FERC determined that ISO-NE has shown that the proposed revisions “appropriately balance the need to mitigate the potential exercise of buyer-side market power against the harms of over-mitigation.” 

FERC said that ISO-NE’s proposal “minimizes the potential for an inefficient overbuild of capacity while providing the necessary time for an orderly transition of the region’s resource mix that will protect reliability and provide market certainty.”

Implementing the MOPR reforms in conjunction with a limited transition mechanism “is a just and reasonable approach in this circumstance because it strikes a reasonable balance among” different considerations raised in the proceeding, including efforts to ensure resource adequacy, minimize potential adverse effects on reliability that could result from an immediate change to the market rules, promote market certainty, and limit the costs associated with over-mitigation.

FERC said that the purpose of the MOPR is to prevent the exercise of buyer-side market power and that it is not a tool designed to maintain reliability. 

The MOPR “does not change the capacity accreditation of resources nor the total amount of capacity targeted in an auction. However, as it does directly change resources’ offers by imposing offer floors, it can impact the clearing price of an auction and alter which resources clear the auction,” FERC said. 

“Therefore, ISO-NE has presented a reasonable case for why immediate removal of the MOPR in ISO-NE could exacerbate existing reliability challenges insofar as a one-time price shock to the capacity market could cause what it describes as the ‘disorderly’ or inefficient retirement of resources that could prove necessary to maintain reliability during extended cold conditions.”

FERC also found that the transition mechanism “promotes market stability and provides a measure of predictability to market participants by specifying the maximum amount of state-supported resources that may clear in FCAs 17 and 18 prior to implementation of the MOPR reforms in FCA 19.”

Commissioners Weigh In

In a concurrence to the order, FERC Chairman Richard Glick said he believes that the best outcome here would have been for ISO-NE to immediately implement its new MOPR, i.e., without the transition mechanism.  

“Simply put, ISO-NE could have, and should have, done better.  Nevertheless, ISO-NE submitted a different proposal—one that delays reform of the MOPR by two years—and we must evaluate the filing before [us],” he wrote.

When considered in that context, Glick believes that the proposed transition mechanism “is part of a just and reasonable package of reforms.” 

In addition, “and critically, the New England States have explained that they do not oppose the transition mechanism,” he noted.

He said he recognizes that the changing resource mix is forcing the Commission, RTOs, and the states to take a new tack to ensuring reliability. “No one can dispute that. But the right way—and, in my view, the only just and reasonable way—to do so is by designing wholesale electricity markets to ensure reliability in light of that changing resource mix rather than trying to roll back the resource mix clock.” 

He said it is not the Commission’s role to choose one resource type over another, or to second guess the wisdom of state resource decisionmaking. “Instead, we must ensure, in a resource-neutral manner, that wholesale electricity markets are procuring the services need[ed] to keep the lights on and the grid in balance.”

As a result of the order, ISO-NE “is free to do just that rather than engaging in a Sisyphean attempt to stymie state efforts through the capacity market.  In this respect, I strongly encourage ISO-NE to move forward expeditiously in developing and filing a capacity accreditation proposal to ensure that the FCM is accurately valuing the capacity contribution of all resources.  Done right, capacity accreditation can serve as a prime example of how Commission-jurisdictional markets can ensure reliability in a manner that compliments, rather than contradicts, states’ exercise of their sovereign authority—exactly the type of ‘cooperative federalism’ that I believe should typify the Commission’s interaction with the states and its regulation of wholesale markets more generally,” wrote Glick.

Commissioners Allison Clements and Willie Phillips offered a joint concurrence. 

“We vote to accept ISO-NE’s tariff filing because it sets the region on course to eliminate the Minimum Offer Price Rule (MOPR), a likely unjust and unreasonable tariff mechanism that, if left uncorrected, could force customers in New England to pay millions or even billions to prop up capacity that they do not want or need,” they said.
While immediate elimination of the MOPR “would likely better serve ISO-NE’s customers than the proposal that has been filed, such a proposal is unfortunately not before us. And at this late hour, nor could the MOPR be immediately eliminated without causing great uncertainty and delay for FCA 17,” wrote Phillips and Clements.

They cautioned “that we believe this proceeding presents unique circumstances, which may not be present in the case of a similar transition mechanism in a different setting.”

Commissioner Mark Christie concurred in approving the filing “due largely to my belief that RTO capacity markets – which are administrative constructs, not true markets — should attempt to accommodate the public policies of the states as long as the impacts, both in costs and reliability, of one or more states’ public policies are not being forced onto other states not sharing those public policies.”

He said that the threat of such impact-shifting to other states in a multi-state RTO was present in PJM’s proposal last year to eliminate its MOPR.

“Here, however, and in distinct contrast to the PJM MOPR proceeding in which Pennsylvania and Ohio expressed strong opposition in a filing in the proceeding, no state in ISO-NE has filed in this record opposing the MOPR’s reform in ISO-NE,” Christie said.

At the same time, he said that while the policy makers of New England “have made their choices and I respect them, I believe that this proposal, even given the transition mechanism, holds the potential for negative effects on the reliability of electric power service in New England and may even cause higher prices for consumers when state officials find it necessary to procure back-up sources of dispatchable power to keep the lights on, as California is now evidently finding it necessary to do.”

Commissioner James Danly dissented from the order, arguing that the filing approved by FERC “ensures that the capacity market in New England will no longer serve any meaningful purpose except to be used as a tool to suppress prices paid to existing generators.  Meanwhile, a fleet of new, state-subsidized renewable resources will force any generator that is not receiving a subsidy—potentially including older renewables—into premature retirement or into expensive, out-of-market reliability must-run contracts (RMR).”

He said he was dissenting “because a market rate design cannot be just and reasonable if it is not competitive, and it cannot be competitive when it permits states to freely manipulate prices. The proposed rate does exactly that and is therefore manifestly unjust and unreasonable.”

Supreme Court Clears Path For Federal Social Cost Of Greenhouse Gas Emissions

May 27, 2022

by Paul Ciampoli
APPA News Director
May 27, 2022

The U.S. Supreme Court on May 26 cleared the way for the Biden administration’s plan to set interim estimates for the social cost of greenhouse gas emissions (GHG) for federal agencies to use.

In March 2022, the U.S. Appeals Court for the Fifth Circuit reversed a federal judge’s decision to grant a motion for a preliminary injunction filed by 10 states that had argued that they will be harmed as a result of an early 2021 Biden administration move to set interim estimates for the social cost of GHG for federal agencies to use. Under the Biden administration, the value for carbon dioxide is about $51 per metric ton, under the prior administration the metric was $1 per ton.

Background

In April 2021, 10 states filed a complaint against the federal government seeking declaratory and injunctive relief as a result of Executive Order 13990 (EO 13990).

EO 13990 reinstated the Interagency Working Group on Social Costs of Greenhouse Gas Emissions. In addition, the Interagency Working Group (IWG) was directed to publish interim estimates for the social cost of carbon, nitrous oxide, and methane — collectively referred to as SC-GHG estimates — for agencies to use when monetizing the value of changes in greenhouse gas emissions resulting from regulations and other relevant agency actions.

The states that filed the complaint are Louisiana, Alabama, Florida, Georgia, Kentucky, Mississippi, South Dakota, Texas, West Virginia, and Wyoming.

A Louisiana-based federal judge agreed with the states and granted a motion for a preliminary injunction filed by the 10 states in February 2022.

In response, the federal government moved to stay the injunction pending appeal arguing, among other things, that the states lack standing, their claims are not ripe, and the interim estimates are not final agency action under the Administrative Procedures Act.

States File Appeal With Supreme Court

In April 2022, the states filed an application with the Supreme Court asking it to vacate the decision issued by the Appeals Court for the Fifth Circuit.

Among other things, the states said that if the Supreme Court did not vacate the Fifth Circuit’s stay order, the Executive Branch will continue using a “made-up, non-statutory metric to arbitrarily tip the scales toward its preferred policy outcome for every activity the federal government touches.”

In effect, the states argued, “that’s everything in modern American life: the SC-GHG estimates implicate rulemakings about the food chain; construction of roads, bridges, and housing; and all energy-related projects and permitting.”

The Supreme Court denied the application filed by the states in a one-sentence issued on May 26. With the states’ application rejected, federal agencies will be permitted to continue to use the interim SC-GHG estimates while the case is ongoing in the Fifth Circuit.

The IWG missed its deadline to issue final estimates for SC-GHGs per EO 13990 and it seems unlikely final estimates will be issued this summer.

On June 21, 2021, APPA in coordination with industry stakeholders submitted joint comments on the “Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990.”  In the comments we requested the IWG ensure the process to update the SC-GHGs is transparent and includes full public participation especially before draft recommendations are issued.

The Associations strongly encouraged the IWG to establish a process that factors in time for a full, robust peer review of any draft revised estimates. The IWG should be clear with the public that the SC-GHG estimates are imprecise, uncertain, and not designed for other applications, such as project level analyses, electricity planning and subsidy schemes and that the original social cost of carbon estimates were developed for use in benefit-cost analyses for regulatory actions. The comments recommended the IWG improve its major modeling assumptions/inputs and presentation of the estimates.

The groups recommended the IWG conduct a formal uncertainty analysis, consistent with the National Academies of Science (NAS) recommendations. Finally, we recommend the IWG develop its own modules to construct an analytic approach that provides a distinct analysis of the domestic costs and benefits, consistent with the NAS report.