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Comments on the 2017 Climate Change Scoping Plan Update regarding Carbon Capture and Sequestration
The authors argue that the Proposed Plan underestimates the readiness and effectiveness of Carbon Capture and Sequestration (CCS). They assert that CCS is technologically viable, citing sixteen integrated projects in North America and the necessity of the technology for deep decarbonization in industrial sectors like steel and cement. The coalition recommends that the Scoping Plan explicitly include CCS for both industrial and power sectors, identify potential synergies with the reduction of toxics and criteria pollutants, and remove regulatory barriers, such as the requirement that carbon capture occur onsite at crude oil production facilities.
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Document type: Statement
Health Risks in Indiana from Oil and Gas Air Pollution
The document details how oil and gas emissions, including ozone smog and toxic air pollutants, cause asthma attacks in children and restricted activity in adults across Indiana, while highlighting the proximity of schools and residents to active oil and gas sites.
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Document type: Fact sheet
GETTING THE MOST OUT OF GRID MODERNIZATION
The document outlines a structured approach to grid modernization, emphasizing integrated distribution planning and the use of outcome-oriented metrics for affordability, resilience, and environmental performance. It suggests tying utility revenue to these performance targets through conditional rates of return or budget caps with shared savings to align utility incentives with public benefits.
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Document type: Research paper
Clean Energy Jobs Growth in the United States
The document reports significant job growth in the U.S. clean energy sector as of early 2016. It highlights that solar and wind industries are expanding rapidly, with solar jobs growing 17 times faster than the overall economy and wind-turbine technicians projected as the fastest-growing occupation. Energy efficiency employs the largest volume of workers at 2.2 million. Geographically, Texas leads in wind jobs, while California leads in solar and energy efficiency jobs.
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Document type: Fact sheet
EXPOSING THE GREENWASH OF THE U.S. CARPET INDUSTRY
The U.S. carpet industry is characterized by high waste, with 89% of discarded carpets ending up in landfills and 6% being incinerated. Despite the existence of the Carpet America Recovery Effort (CARE), only 1% of carpet waste is recycled back into carpet in a closed loop. The report argues that major manufacturers, particularly Shaw and Mohawk, engage in greenwashing and actively lobby against Extended Producer Responsibility (EPR) legislation to maintain a wasteful linear model. In California, the AB 2398 law has failed to achieve meaningful recycling increases because it relies on consumer fees rather than producer funding, and is administered by CARE, which the report claims is under the influence of the industry's largest players.
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Document type: Report
Illinois Can Meet its Clean Power Plan Targets in 3 Steps
Illinois can achieve 75% of its Clean Power Plan target by following existing clean energy policies and improving fossil plant efficiency, and can exceed the target by expanding efficiency and renewable standards.
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Document type: Fact sheet
DESIGNING A PERFORMANCE INCENTIVE MECHANISM FOR PEAK LOAD REDUCTION: A STRAW PROPOSAL
The paper argues that traditional cost-of-service regulation incentivizes utilities to invest in capital expenditures to meet peak demand. To counter this, it proposes a PIM based on an outcome-oriented metric—specifically the percentage reduction in peak load—rather than a measure-by-measure counterfactual approach, which it claims failed in California's Risk Reward Incentive Mechanism (RRIM). The author recommends setting long-term targets (five to eight years) with annual interim goals and utilizing a sloped, symmetrical incentive structure with upper and lower caps. To manage risk, the proposal suggests a gradual implementation starting with small revenue amounts, eventually scaling the PIM based on independent studies of the net societal benefits of peak reduction.
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Document type: Research paper
illinois_cpp_letter_3.2.16-2b477cf9d3ba7e6d.pdf
A coalition of energy and environmental organizations advocates for the use of energy efficiency to meet Illinois' Clean Power Plan compliance limits, arguing it is the cheapest and fastest way to reduce emissions while creating local jobs and saving consumers money.
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Document type: Statement
Meeting the Clean Power Plan in Illinois
The Union of Concerned Scientists argues that Illinois can cost-effectively meet its Clean Power Plan (CPP) target—reducing carbon emissions by 34 percent below 2012 levels by 2030—by adopting a "Clean Path Case." This approach involves strengthening the state's renewable portfolio standard (RPS) and energy efficiency portfolio standard (EEPS) alongside a mass-based emissions trading program. The analysis suggests this pathway would yield nearly 6,000 MW of new wind and solar capacity, reduce typical household electricity costs by 9.4 percent by 2030, and generate $14.3 billion in cumulative health and economic benefits through 2030 by reducing CO2, SO2, and NOx pollution.
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Document type: Report
Meeting the Clean Power Plan Technical Appendix
The Union of Concerned Scientists (UCS) utilized the National Renewable Energy Laboratory's (NREL) Regional Energy Deployment System (ReEDS) to assess the Clean Power Plan. The analysis incorporates modified cost and performance assumptions for various energy technologies, including a rejection of EIA 'learning' curves for mature technologies and specific adjustments for nuclear, coal, and renewables. The study compares four scenarios: a Reference Case, a CPP National Trading Case, a CPP No Trading Case, and a 'Clean Path' Case involving enhanced state-level policies in Illinois, Michigan, Minnesota, New Mexico, Pennsylvania, and Virginia.
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Document type: Report
ENVIRONMENTAL JUSTICE STATE GUIDANCE FOR CLEAN POWER PLANNING
The document outlines strategies for US states to ensure that the Clean Power Plan does not disproportionately burden low-income communities and communities of color. It emphasizes the need for 'high impact' engagement, the conduct of formal Environmental Justice (EJ) analyses, and the avoidance of carbon trading mechanisms that may allow power plants to avoid on-site pollution reductions. The guide also advocates for a 'Just Transition' that provides economic development and job training in communities heavily dependent on fossil fuels.
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Document type: Guide
Connecting Local Farmers and Large-Scale Food Buyers to Create Jobs and Revitalize America’s Heartland
The document examines the decline of midsize family farms in the U.S., using Iowa as a primary case study, and proposes a national food policy to connect these farms with institutional buyers to create jobs and improve environmental sustainability.
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Document type: Policy brief
Why We Should Invest More in the Transition to Sustainable Agriculture
The document assesses the level of federal investment in sustainable agriculture, specifically agroecology, using a five-level classification system. It finds that the vast majority of USDA funding supports incremental efficiency gains rather than transformative agroecological practices. The authors call for increased funding and a shift toward systems-based research that integrates ecological and socioeconomic sustainability.
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Document type: Fact sheet
WHO SHOULD OWN AND OPERATE DISTRIBUTED ENERGY RESOURCES?
The paper examines how different DER ownership models can be used to integrate cost-effective technologies into outdated regulatory frameworks. It argues that no single model is universal, but each can work if the value proposition aligns with the public interest and utilizes an adaptive approach prioritizing fair compensation and transparency. Utility-owned models are effective for early adoption and public goals but risk cost overruns and market power issues. Third-party and customer-owned models excel when they have transparent access to the full value of DERs through dynamic rate design or competitive markets.
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Document type: Research paper
THE ECONOMICS OF DEMAND FLEXIBILITY
The report argues that demand flexibility—the use of technology to shift electricity use across hours of the day—can significantly lower both customer bills and grid investment costs. In the U.S. residential sector, it could avoid $13 billion annually in grid and energy costs while reducing customer bills by 10–40%. The analysis highlights that 'flexiwatts' from appliances like air conditioning and water heaters can reduce peak demand and better integrate renewable energy. However, the report warns that demand flexibility may accelerate 'load defection' if utilities reduce compensation for exported rooftop solar PV.
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Document type: Executive summary
THE ECONOMICS OF DEMAND FLEXIBILITY
The report analyzes 'demand flexibility' (DF)—the use of technology to shift electricity loads like air conditioning and EV charging to lower-cost times. It finds that widespread residential DF could avoid $13 billion annually in U.S. grid costs and reduce customer bills by 10–40%. Through four case studies (ComEd, SRP, HECO, and Alabama Power), the report demonstrates how DF can mitigate peak demand, integrate rooftop solar PV, and provide a lower-cost alternative to traditional grid infrastructure investments.
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Document type: Report
Administrative Appeal of the Final Rule: “Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains,” Docket No. PHMSA 2012-0082 (HM-251), 80 Fed. Reg. 26,644 (May 8, 2015)
Earthjustice and a coalition of local governments and environmental groups are appealing the 'Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains' final rule. They contend that the rule violates the Administrative Procedure Act by abandoning the notification requirements of the May 2014 Emergency Order without public comment. The appeal argues that the new system—which relies on rail routing analysis and voluntary industry practices—provides retrospective, aggregated data that is less useful to first responders than the weekly, county-level notifications previously required. Furthermore, the petitioners argue that the DOT is improperly restricting public access to train route information by treating it as sensitive security or confidential business information without a legal basis.
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Document type: Statement
An Open Letter on Clean Energy
A group of 53 Illinois scientists, engineers, economists, and health professionals argues that the state's clean energy progress has stalled due to policy flaws. They advocate for increasing the renewable energy target to 35% of electricity and energy efficiency investments capable of reducing demand by 20%, while calling for a market-based approach from the Illinois EPA to reduce carbon emissions.
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Document type: Statement
Opposition to “H.R. 1734, Improving Coal Combustion Residuals Regulation Act of 2015”
A coalition of 290 organizations and individuals opposes H.R. 1734, asserting that the bill would weaken the U.S. Environmental Protection Agency's (EPA) 2014 coal ash rule. The signatories argue the legislation would delay health protections, eliminate public access to information, and remove national standards for drinking water protection, thereby increasing risks to vulnerable communities and the environment.
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Document type: Statement
Achieving Illinois’s Clean Energy Potential
The document details the use of the NREL Regional Energy Deployment System (ReEDS) model to evaluate three policy scenarios for Illinois: a 'No Policies' case, an 'Existing EEPS + Fixed RPS' case, and a 'Strengthened EEPS + RPS' case. It outlines specific adjustments made to EIA AEO 2014 cost and performance assumptions for various generating technologies, including wind, solar, nuclear, and carbon capture and storage, to better reflect project-specific data and recent studies. Additionally, it provides the calculation methods for energy efficiency costs and savings based on Illinois utility filings.
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Document type: Report