Studies, Reports & Commentary

October 1, 2018

ERCC Testimony on EPA's ACE Rule
RE: Emission Guidelines for Greenhouse Gas Emissions From Existing Electric Utility Generating Units; Revisions to Emission Guideline Implementing Regulations; Revisions to New Source Review Program

application/pdf iconERCC Comments on ACE Proposal.pdf
April 30, 2018
ERCC Submits Comments on Clean Power Plan Repeal
The Electric Reliability Coordinating Council submitted comments on the Clean Power Plan repeal last Thursday as the deadline closed.  ERCC argued 1) the CPP went well beyond EPA’s Authority under Section 111(d) of the Clean Air Act; 2) CPP Is fundamentally inconsistent with the Cooperative Federalism Principles that Congress established in the CAA and other Federal Statutes; 3) the Clean Power Plan is just bad policy because it jeopardizes electric supply and harms consumers whiel essentially doing nothing to reduce climate change.  Finally, ERCC said it supports efforts for EPA to  replace the CPP with regulations based on sound legal and economic principles. “Such an effort would provide regulatory certainty, diminish frivolous litigation, and aide the planning efforts of power companies and state utility commissions.”

 

application/pdf iconERCC CPP Repeal Comments - April 26, 2018.pdf
November 27, 2017

ERCC Statement at the Nov. 28 2017 EPA Public Hearing on CPP Repeal (Charleston, WV)

application/pdf iconERCC Statement at the Nov. 28 2017 EPA Public Hearing on CPP Repeal (Charleston, WV).pdf
August 31, 2017

Supreme Court Amicus Curiae Brief of ERCC & UARG in Support of Petitioners - At this location you can find an amicus brief filed in the application for cert made to the Supreme Court by DTE.  The case deals with the definition of emissions increase under the NSR program.   Filed on behalf of ERCC and UARG, we think you will find it a useful review of the principal NSR policy arguments – it is intended as a policy context for the legal arguments presented in the DTE Supreme Court petition.  The brief is relatively short and represents the first time the new DOE Grid Reliability report has been brought to the attention of the Supreme Court.  

application/pdf iconSupreme Court Amicus Curiae Brief of ERCC, UARG in Support of Petitioners.pdf
August 21, 2017

Nuclear Energy, the Production Tax Credit, and International Security, by CDR Kirk S. Lippold, USN (Ret) - CDR Kirk Lippold, USN (Ret), a noted expert on energy security, offers insightful analysis on the relationship between a robust civilian nuclear sector, international security considerations, including important commitments made to the State of Israel after the Iranian nuclear agreement. He argues for a conducive environment for nuclear development as reflected in appropriate production tax credits. Lippold served at the International Strategy Division in the Office of the Chief of Naval Operations, is a graduate of the United States Army Command and General Staff College and the Joint Forces Staff College, and was the Commanding Officer of USS Cole (DDG 67) when it survived a suicide terrorist attack by al Qaeda.

application/pdf iconNuclear Energy, The Production Tax Credit, and International Security.pdf
July 31, 2017

ERCC's Letter to Senate Majority Leader McConnell on Restoration of FERC Quorum

application/pdf iconNeed to Restore the Federal Energy Regulatory Commission (FERC) Quorum as Soon as Possible.pdf
August 3, 2015

 ERCC Answers Ten Important Questions You Should Have About EPA's Final Rule on Carbon Emissions from Power Plants

application/pdf iconERCC Answers Ten Important Questions You Should Have About EPA's Final Rule on Carbon Emissions from Power Plants.pdf
March 14, 2012

ERCC White Paper EPA Power Sector Rule Increases the Cost of Gasoline Production and Decreases the Diversity of US Energy Production – Version 2.0

application/pdf iconEPA Power Sector Rule Increases the Cost of Gasoline Production and Decreases the Diversity of US Energy Production - Version 2.0.pdf
December 1, 2011

ERCC White Paper on DOE Analysis on Reliability and EPA Rule

application/pdf iconERCC White Paper on DOE Report.pdf
July 17, 2011

The Economic Impacts of Coal Utilization and Displacement in the Continental United States, 2015 prepared for the Center for Energy and Economic Development, Inc.


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June 25, 2011

NERA Economic Consulting Analysis of EPA’s Proposed CATR and MACT


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May 16, 2011

The Need for Legislative Action to Phase in EPA Regulations on Clean Air Act, Statement of Edwin D. Hill, International President, International Brotherhood of Electrical Workers


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