A number of states, cities, and power companies plan to press forward with clean energy efforts despite this week’s Supreme Court stay of the Clean Power Plan.
That’s because the future of carbon regulation is not “if” but “how and when,” and it is too big a question not to continue a thoughtful conversation among thoughtful people.
States to explore options
Officials in states including California, Colorado, Minnesota, Virginia, and Washington have said the court’s temporary stay won’t stop them from continuing to explore implementation options, which include leveraging the power of market forces to reduce emissions. Even states suing the Environmental Protection Agency (EPA) have been having these conversations, and most will continue to.
For instance, Montana Department of Environmental Quality energy bureau chief Laura Andersen told ClimateWire, "The market forces at play in the region are quite significant and will not go away just because the Clean Power Plan has a stay on it.”
Al Minier, chairman of the Wyoming Public Service Commission, said the stay could give regulators more time to develop strategies that are best for the state.
Weathering the Next Storm: A Closer Look at Business Resilience
Extreme weather and other climate-related impacts are becoming more frequent, and are imposing real costs on communities and companies. Companies have always navigated a changing business environment. But now they face a changing physical environment, as climate change affects their facilities and operations, supply and distribution chains, electricity and water, and employees and customers.
A new 2015 C2ES Report, Weathering the Next Storm: A Closer Look at Business Resilience, examines how companies are preparing for climate risks and what is keeping them from doing more. It also suggests strategies for companies and cities to collaborate to strengthen climate resilience.
The new report synthesizes public disclosures by S&P Global 100 companies, in-depth interviews and case studies, and workshops. It updates the groundbreaking 2013 report, Weathering the Storm, Building Business Resilience to Climate Change, which provided a baseline for how companies were assessing their climate vulnerabilities.
|Click above to see our Weathering the Next Storm infographic, with key takeaways|
- Most major companies recognize and report climate risks. Ninety-one percent of companies in the S&P Global 100 Index see extreme weather and climate change impacts as current or future risks to their business.
- Companies worry about climate impacts beyond their facilities. Almost all companies interviewed expressed concern about impacts to their supply chains and public infrastructure.
- There isn’t one right way to assess and manage climate risks. Many companies view climate change as a “threat multiplier” that exacerbates existing risks. This puts climate change into a familiar context, but could cause companies to overlook or underestimate the threats they face.
- Companies struggle to translate long-term, global climate data into short-term, local risks. Despite growing access to climate-related data and tools, companies say they need “actionable science” that helps them understand locally-specific risks or risk scenarios.
- Companies can start with a limited-scope vulnerability assessment – focusing, for example, on the most critical parts of the business – to raise internal awareness of climate risks.
- Companies should facilitate regular communication across departments involved in climate risk and resilience -- including sustainability, risk management, operations, and finance – and consider whether to change planning horizons to better incorporate climate risks.
- Companies, state and city governments, non-profits and local experts should explore partnerships to analyze data, evaluate climate risks, undertake cost-benefit studies, and implement resilience planning.
- Governments should look for ways to streamline climate risk reporting and provide more guidance on how to incorporate climate risks into financial disclosures.
- Governments should improve public infrastructure and provide opportunities for the private sector to contribute to resilience planning efforts and investments.
- Fact Sheet: Key Insights on Business State and City Collaboration for Climate Resilience
- Executive Summary of our 2015 report.
- Press release on the 2015 report.
- Blog: Are Businesses Prepared for Climate Impacts?
- Our 2013 report and infographic: Weathering the Storm, Building Business Resilience to Climate Change
- Slides from December 2, 2015 webinar for California’s Alliance of Regional Collaboratives for Climate Adaptation
- Video on our YouTube page from our 2013 presentations on Weathering the Storm: Building Business Resilience to Climate Change
- Business Resilience Workshop, March 24, 2015, Washington D.C.
- Climate Impacts and Resilience Workshop, July 26, 2014, Washington, D.C.
- The Executive Forum on Business and Climate, November 3-4, 2013.
- Business Resilience Webinar Series, September-December 2013.
- USA TODAY op-ed by National Grid US President Tom King and American Water CEO Jeff Sterba.
- Our Sept. 23, 2013, event at Climate Week NYC: agenda, photos, video interviews with speakers Preston Chiaro of Rio Tinto; Ken Daly of National Grid, New York; Alan Kreczko of The Hartford; and Lisa Shpritz of Bank of America.
- Our 2008 study, “Adapting to Climate Change: A Business Approach," which outlined an initial screening framework for assessing risks.
Video: Webinar for California’s Alliance of Regional Collaboratives for Climate Adaptation, December 2, 2015
Video of our report launch
Building Resilience to Climate Change -- Why it's Crucial
Panel: Taking Business Resilience to the Next Level
Comments of the Center for Climate and Energy Solutions on the Clean Power Plan's Clean Energy Incentive Program
C2ES December 2015 comments of the Center for Climate and Energy Solutions on the Clean Power Plan’s Clean Energy Incentive Program (CEIP)
This document constitutes the comments of the Center for Climate and Energy Solutions (C2ES) on the proposed Clean Energy Incentive Program proposed by the U.S. Environmental Protection Agency (EPA). C2ES is an independent, nonprofit, nonpartisan organization dedicated to advancing practical and effective policies and actions to address our global climate change and energy challenges. As such, the views expressed here are those of C2ES alone and do not necessarily reflect the views of members of the C2ES Business Environmental Leadership Council (BELC).
C2ES believes that market-based policies are the most efficient and effective way of reducing greenhouse gas emissions, and we applaud EPA for including multiple provisions in the final Clean Power Plan that promote market adoptions that can be used by states. Market-based policies harness market forces to spur innovation, development and deployment of clean energy technologies. To that end, trading of allowances or emission rate credits (ERCs) under the Clean Power Plan (CPP) can help ensure that emission targets are achieved at the lowest possible cost. Complementary to this, C2ES believes the Clean Energy Incentive Program (CEIP), properly designed, can help meet CPP objectives, promote market mechanisms and provide additional clean energy benefits as outlined below.
The CEIP provides economic value
CEIP credits (allowances or ERCs) issued by states and matched through EPA’s reserved pool could provide economic value to clean energy projects in two ways. First, if a project developer is an electricity generator subject to the CPP, these credits can be used for compliance. Second, if the project developer does not have a compliance obligation, these credits can be sold, which creates a revenue stream that can improve the financial viability of a project. As states develop their implementation plans, they may be able to provide early enhancements for project financing if some of the CEIP credits are allocated in advance by project type. This can help mobilize capital markets who would now know that the additional incentive would be available.
The CEIP will accelerate early market formation and price discovery
CEIP credits will complement other trading mechanisms that states may establish to comply with the CPP and add additional liquidity to CPP markets. Liquidity is important to an emissions trading market because it lowers the risk of price volatility or sudden price spikes caused by an inability to find available allowances. In addition, it can help with price discovery because these will likely be available before CPP compliance markets are functioning.
The trading of CEIP credits could be a key strategy for electricity generators to comply with emissions limits, either by incentivizing them to reduce their emissions and sell (or avoid purchasing) credits, or by purchasing credits from other generators at a lower cost. Early implementation of the CEIP may play a role in fostering the development of these trading regimes.
The CEIP could speed the development of state implementation plans and help reduce regulatory uncertainty
Projects become eligible for CEIP credits only if they commence construction after a final state implementation plan is submitted in the project’s host state. EPA allows plans to be finalized as late as September 2018. Because of the value of CEIP credits, project proponents may encourage states to finalize plans as soon as possible in order to open CEIP eligibility to a greater number of projects. Early plan finalization may give utilities additional time to plan for compliance and lower the regulatory uncertainty around CPP implementation.
The CEIP can incentivize city-level clean energy programs
Finally, the CEIP could provide a way for cities to have a role in meeting CPP compliance goals. U.S. cities have tremendous citizen and policymaker interest in reducing carbon emissions, improving energy efficiency and deploying more renewable energy, but they often face resource constraints. CEIP credits could provide cities a crucial funding resource to expand existing programs or launch new initiatives.
While noting that the CEIP as proposed has many benefits, C2ES also sees several potential enhancements, and we recommend the following:
Ensure the maximum number of projects can receive credits under the CEIP
Opportunities for wind, solar, and energy efficiency projects abound, and there is a chance that the demand for credits will exceed 300 million tons. We advise EPA to prepare for this situation by anticipating how to allocate credits when there are not enough to match each megawatt hour generated or avoided.
One way to accomplish this is to provide a reservation system for credits. Clean energy project developers would request credits prior to 2020, based upon two requirements—the launch of the program/beginning of construction and the expected performance of the project. In 2020 and 2021, after the project’s performance is verified, the project could then be allocated credits. C2ES believes this would add certainty to the project financing during the development stage by reducing the chance that a project would receive no credits (because the CEIP pool had been depleted), as could happen under a first-come, first-served system. EPA or states could also modify a reservation system to achieve other policy aims by prioritizing projects that meet desired characteristics. For example, criteria could include project size, project cost, or project operation start date. This approach can help mobilize capital markets earlier.
An alternative approach would be to set a maximum number of credits that a project could request from the CEIP. In this way, an allocation to a large project would not leave too few credits for other projects. A system could be developed where allocation requests happened in stages, so that if, after all eligible projects had received credits for some fraction of the electricity generated or avoided, they could request additional allocation if credits remained in the CEIP matching pool. This is different than the redistribution formula on which EPA is requesting comment, in that this staged distribution would occur in the same year in the same state and applies only to the situation in which the CEIP is oversubscribed.
We recognize that setting a priority to maximize the number of projects that receive CEIP credits creates a risk of missing opportunities for least-cost project development. Giving a large number of CEIP credits to a small number of projects may be more cost effective because it may result in lower costs for project administration per unit of renewable energy or energy efficiency delivered. However, given the limited duration of the CEIP, C2ES believes that the environmental benefits of broad participation outweigh the economic concerns of possibly incentivizing more costly programs over less costly ones.
SPECIFIC COMMENTS REQUESTED BY EPA
EPA requested comment on a number of provisions in the proposed CEIP. C2ES thanks EPA for the opportunity to comment on a few of these areas.
Definition of commence construction
C2ES believes EPA should use a definition of “commence construction” that already exists. This lowers the administrative costs of the CEIP and facilitates faster deployment of CEIP-eligible projects, since developers would not need to educate themselves about a unique definition.
As an example, certain federal-level clean energy tax credits define “commence construction” as when either work of a significant physical nature has been undertaken or more than 5 percent of a project’s total capital cost has been spent. Such requirements are well-understood by project developers and are not considered overly burdensome to meet or demonstrate to authorities.
Definition of low-income community
Similarly, C2ES believes EPA should use a definition of “low-income community” that already exists. State and city policymakers and project developers are familiar with existing terms, for example a geographic region’s area median income, or a comparison to the federal poverty line. While we are agnostic on exactly which definition is used, we believe it should be one currently used in other federal programs, reflecting regional differences in cost of living, and consistent across all states.
C2ES identifies a second aspect of the low-income community definition under the CEIP that we believe should be changed – the prescribed extent in which low-income communities are served. Some projects serve only low-income communities, for example residential energy efficiency improvements. Others, however, serve the broader community, including low-income households. For example, energy efficiency projects at water treatment plants serve the broader community, including low income households.
C2ES believes that applying a broad definition of how communities are served will maximize the environmental and economic benefits of the CEIP. It will do this by increasing the number of projects that are eligible – some of which may be larger and therefore lower cost to implement. Energy efficiency tends to lower electricity bills as consumers who have deployed more energy efficient technologies reduce their consumption of electricity. This provides an additional benefit that can significantly help low-income communities given the regressive nature of any energy cost increase. In addition, it has the added benefit of making these consumers less vulnerable to extreme heat or cold.
Evaluation, measurement, and verification requirements should be explicit and consistent
C2ES recognizes the critical role that evaluation, measurement, and verification (EM&V) requirements play in maintaining the environmental integrity of carbon trading programs. Having EPA-defined EM&V requirements reduces potential costs for state agencies by avoiding the need to develop requirements in every state and provides consistency for project developers as part of the model rule.
C2ES recommends that as EPA finalizes the EM&V requirements, it should prioritize processes that are low-cost and can be applied uniformly across states to allow a greater deployment of energy efficiency under the CPP.
Timing of credit allocation
C2ES notes that having credits available to the market as early as possible is the best way to reduce uncertainty and stimulate early market formation. In terms of credit allocation to projects in 2020 and 2021, C2ES recommends that EPA provide matching credits to clean energy projects shortly after performance, potentially on a quarterly or six-month basis.
Redistributing unused credits
If there are insufficient projects in a state to utilize its full share of EPA’s matching pool, C2ES recommends that the credits be available to projects in any state in which the CEIP is implemented and there is excess demand for credits, on a first-come, first-served basis. The initial matching pool allocation to participating states will ensure that states with a large capacity for clean technologies do not utilize the entire pool at the expense of states with smaller capacities. However, if a state’s share of the matching pool is unused, this would most likely reflect capacity that is too expensive to develop in the 2020-2021 timeframe. C2ES believes the EPA matching credits should then be rewarded to projects in other states that have met eligibility criteria but have not yet been allocated credits (reflecting an oversupply of economic renewable and energy efficiency potential in that state).
Converting the 300 million short ton matching pool into ERCs
C2ES believes that such a conversion should be administratively simple and consistent with the actual emission reductions taking place on the electricity grid. For example, the emission rate of the marginal generation source in a given power market could be used. In addition, C2ES recommends that the conversion factor be periodically updated to account for the expected change in carbon intensity of electricity generation occurring even before the first compliance period. For example, if new renewables lowered the carbon intensity (in tons/MWh) of electricity in a power market between 2020 and 2021, the conversion factor (expressed in tons/MWh) would have to be similarly lowered so that projects receiving ERCs or allowances are treated fairly, with respect to one another.
Participation by states, tribes and territories without CPP goals
Since CEIP-eligible projects serve to reduce overall emissions of the entire electricity grid, it is appropriate to allocate CEIP credits to projects in states that do not have CPP goals but are connected, via interstate transmission lines, to states that do. These jurisdictions, if they wish to participate in the CEIP, should submit an intent to do so in the same way as CPP states. EPA should then allocate a portion of its matching pool to these jurisdictions using the same formula as for other states. Since there is no corresponding state match for these jurisdictions, EPA could consider doubling the allotment from the federal matching pool for projects in these jurisdictions only. In this way, project developers would have an equal incentive to develop CEIP-eligible projects in these jurisdictions. For example, an energy efficiency project located in the District of Columbia could be granted two full CEIP credits from the EPA matching pool for every megawatt hour of electricity avoided. In this way, the project receives the same economic incentive as a project located in a state with a CPP target.
C2ES recognizes that EPA has finalized the eligibility criteria in the final Clean Power Plan. As mentioned earlier, the CEIP has the potential to be an important stimulator of clean energy and also of market-based implementation plans. We view these as important and that the CEIP can play this role.
However, in finalizing the eligible projects to solar, wind, and energy efficiency in low income communities, EPA is making some essential policy advances, but at the same time missing some others.
Encourage other clean energy technologies
C2ES believes that the CEIP as proposed encourages other clean energy technologies too narrowly. For example, hydropower and geothermal facilities could increase capacity at existing plants within a similar two-year construction window, while carbon capture and storage (CCS) could be deployed at existing coal and natural gas units to significantly decrease emissions.
We suggest that EPA explicitly help states to understand and use the flexibility they have in their overall state-wide allocations to complement the objectives of the CPP and CEIP, including rate payer protection, and potentially allocations for other clean energy technologies. Each state is unique, with its own set of industries, resources and population needs. For example, we believe one state may desire to buffer rate impacts, while another might want to use a portion of its allocation to credit a CCS retrofit or capacity upgrade at another existing power plant. We believe that states should have as much flexibility as possible.
Related to this issue, states should also be granted the flexibility to determine how many CEIP credits to allocate to clean energy or energy efficiency technologies from their state budgets. For example, under the proposal, a wind project would receive half credit from a state and half credit from EPA, for every megawatt hour generated. If a state wanted to give a wind project a full credit, for example, we see no issue (even if EPA only provides a half of a credit). Similarly, if a state deems CCS to be eligible for CEIP allocation, but EPA does not, then a state should be able to decide the size of the credit for the the CCS project. In this way, the megawatt hour generated from wind and the CO2 reductions from CCS would receive the same economic incentive, even though the source of this incentive (state versus EPA) would be different.
November 12, 2015
Contact: Marty Niland, email@example.com, 703-516-0600
Fleet operators could save money with natural gas vehicles
WASHINGTON – Public and private fleet operators could save money by switching to natural gas vehicles using the business model that energy service companies (ESCOs) apply to energy efficiency projects, according to a guide released today by the Center for Climate and Energy Solutions (C2ES).
Although switching to natural gas vehicles (NGVs) can lower costs, many fleet managers have not converted their fleets. Strategic Planning to Enable ESCOs to Accelerate NGV Fleet Deployment: A Guide for Businesses and Policymakers helps investors and state and local policymakers make decisions about deploying natural gas vehicles in public and private fleets, which are among the most initially promising areas.
The findings are part of a two-year initiative, in partnership with the National Association of State Energy Officials (NASEO) and with funding from the U.S. Department of Energy’s Clean Cities Program, to develop innovative finance mechanisms aimed at accelerating the deployment of alternative fuel vehicles and fueling infrastructure.
The guide analyzes the cost-saving potential for switching tractor-trailer truck, school bus, and light-duty vehicle fleets. Among the key findings:
- Incorporating natural gas vehicles into fleets can significantly reduce petroleum use and harmful emissions, especially with tractor-trailer fleets.
- The major factors affecting the financial performance of natural gas vehicle fleets are the fleet’s vehicle technology and vehicle usage patterns.
- Natural gas vehicle projects for tractor-trailer fleets result in net cost savings under nearly every fleet size and travel scenario considered in the guide’s analysis.
- Using natural gas to fuel school bus fleets also results in net cost savings for fleets whose vehicles travel about 20,000 miles per year.
- An energy service provider can help with the transition to natural gas by familiarizing fleet managers with new technology, identifying a project’s greatest savings potential, reducing financial risk, and helping maximize financial payoff.
“Switching from diesel to natural gas is a net cost-saver for fleets in many cases. But even the most cost-conscious fleet manager can hesitate to switch to a new technology, especially in a time of low oil prices,” said Nick Nigro, a C2ES senior advisor and lead author of the report. “The fleet market can learn a lot from ESCOs and how they’ve deployed energy efficiency technologies by offering valuable services and training in exchange for a share of the cost savings.”
“Many of NASEO’s members, the 56 State and Territory Energy Offices, are eager for solutions and strategies supporting the use of domestic and clean transportation fuels,” added David Terry, Executive Director of NASEO. “The Strategic Planning Guide is an important addition to states’ toolboxes in their efforts to reduce reliance on imported oil, improve air quality, and stimulate economic growth.”
Read the report.
Learn more about the initiative.
The Center for Climate and Energy Solutions (C2ES) is an independent, nonprofit, nonpartisan organization promoting strong policy and action to address our climate and energy challenges. Learn more at www.c2es.org.
More than 300,000 electric vehicles (EVs) are already on the road in the United States, but to ramp up adoption of this technology, consumers will need more access to charging beyond their home or office.
C2ES has identified business models that, combined with near-term public support, could boost investment in publicly available EV charging and expand the environmental benefits of EVs.
The business models are detailed in a new C2ES publication, Strategic Planning to Implement Publicly Available EV Charging Stations: A Guide for Businesses and Policymakers. The guide draws on research from a two-year initiative in partnership with the National Association of State Energy Officials (NASEO) to explore innovative financing mechanisms aimed at accelerating the deployment of alternative fuel vehicles and fueling infrastructure.
Strategic Planning to Implement Publicly Available EV Charging Stations: A Guide for Businesses and Policymakers
Can you feel the momentum?
With negotiators meeting in Bonn this week and only six weeks to go until Paris, the business community is not only stepping up to the plate, but is swinging for the fences on its support climate action (Yes, it’s playoff season, so baseball is also on my mind).
This week’s announcement that 69 companies have joined the White House’s American Business Act on Climate Pledge brings the total to 81. Many of these companies pledging to reduce their emissions, take other actions to tackle climate change and support a strong international agreement include a number of members of our own Business Environmental Leadership Council: Alcoa, Bank of America, GE, General Motors, HP, IBM, Intel and PG&E. Together the 81 companies represent a combined $3 trillion in revenue and 9 million employees.
And last week, 14 companies with a combined revenue of $1.1 trillion and 1.5 million employees signed a statement organized by C2ES in support of a Paris climate agreement, that began “Paris presents a critical opportunity to strengthen efforts globally addressing the causes and consequences of climate change, and to demonstrate action by businesses and other non-state actors. ”
But these companies aren’t just talking about climate change; they’re doing something about it. They’re making commitments to reduce their own emissions, and some are even committing to use 100% renewable energy through the RE100 campaign. They are also working both internally and with communities and cities to increase climate resilience.
Now it’s time to take this enthusiasm and put it to work. We know there is growing support for a strong agreement in Paris, and hopefully that’s what we’ll get in December. But that’s just the first step—we’ll need to ensure that countries live up to their commitments, and back here in the United States, we’ll be working with businesses, states, and cities to build partnerships that harness the power of the markets to reduce emissions, develop innovative financing for clean energy and strengthen our resilience to climate impacts.
We have some real momentum going now. Let’s make the most of it.
Cities and counties are increasingly emerging as climate leaders, becoming laboratories and incubators for climate solutions. These solutions take a fresh approach to emerging local challenges, and could drive progress at a larger scale.
Here are two key ways cities are stepping up:
· Local governments are creating an invaluable knowledge base for efficiency and sustainability efforts.
To reach your destination, you have to know where you are starting from. That’s why it’s so important that cities are taking advantage of ever-improving data collection and analytical capabilities to become the providers of rich databases of energy and water use in their jurisdictions.
Philadelphia's Energy Benchmarking program requires large commercial buildings to disclose their energy use. As a result, the city has a baseline of energy usage by nearly 2,000 buildings across multiple sectors. By sharing this data with building owners and energy managers, the city is focusing more attention on saving energy. And by sharing building data online with potential tenants, the city hopes to create a market for efficient buildings.
A similar program in New York City has had promising results. The disclosure policy corresponded with energy savings of nearly 6 percent - worth more than $260 million.
Photo by Amy Morsch
A volunteer from Escola University uses a model home to demonstrate energy-saving tactics at the first Brazilian Alcoa Green Fair in Poços de Caldas.
Seeing is believing, even if it’s a meticulously built model used to illustrate action in real life.
Take the model home Escola University volunteers displayed at a recent Alcoa Green Fair in Poços de Caldas, Brazil. From top to bottom, it demonstrated energy-saving actions in every nook to help visitors see how each small change can save kilowatts -- and money.
Communities can use the same concept to illustrate and communicate what actions will help save energy and reduce climate impacts.
The way we talk about climate and energy issues can either empower people to act or leave them overwhelmed. People won’t necessarily be moved to act just because they know about the challenges. More often, they will be moved because they feel a collective responsibility for a shared problem and understand how they can make a positive impact.
Through the Alcoa Green Fairs, C2ES and the Alcoa Foundation work to drive action on climate and energy issues in a positive and engaging way. Now, Alcoa and C2ES have pushed this successful U.S. program to the international stage. The first-ever fair in Brazil in August attracted 17 organizations and more than 750 people to Alcoa’s Poços de Caldas plant, about four hours north of the capital Sao Paulo, to see demonstrations, learn about resources, and discover new ways to be eco-friendly.
Events like the Alcoa Green Fairs highlight how organizations are stepping up to reduce their impacts, both collectively and one employee at a time. This leadership was evident when Alcoa plant managers, employee champions, the Alcoa Foundation, C2ES, and Sustainable Poços Association (APS) gathered at an early-morning roundtable discussion before the fair.
Weathering the Next Storm:
September 22, 2015
By Katy Maher and Janet Peace
Infographic with key takeaways
Increased extreme weather and climate-related impacts are imposing significant costs on society and on companies. While businesses are increasingly taking steps to assess risks and prepare for future climate changes, many companies face internal and external challenges that hinder efforts to move toward greater climate resilience. Building and expanding on an earlier review completed in 2013, C2ES examined how large companies are preparing for climate risk, who they are partnering with, and what is keeping them for doing more.