Policy Studies

From Shale to Ship: The Potential for Lower Carbon U.S. LNG Production

LNG Terminal and Carrier

The author argues that the production of lower-carbon US LNG will occur with or without the cooperation of the LNG, oil, and natural gas industry. However, this transition will be less costly and happen faster if US companies change decades-old practices and how they approach the siting of LNG and interstate natural gas pipelines. Read full article in the Climate and Energy Journal. Read more

US and Global Energy Security: Where We Are Falling Short

Achieving Energy Security takes a lot of effort

If it wasn't for my editor Echo Carthright, I would have titled this article the Energy Transition: All the Wrong Stuff. That said, I really believe the efficiency and capacity factors of current power technologies are insufficient to achieve net zero carbon emissions in most countries. Besides, a fossilize National Environmental Policy Act in the US and similar laws in other countries, NEPA  will stifle construction of needed projects even if they are renewable energy and clean electric transmission.

Business as usual will not do. What's needed is serious basic and applied net zero energy research (similar to what was used to develop mRNA Covid-19 vaccines) that revolutionizes power technologies and environmental impact assessment. The latter includes standardized mitigation for most energy infrastructure projects rather than a bespoke process that makes believe this is the first time a federl agency is evaluating a given project, whether it be hydropwer, wind, solar, electric transmission, natual gas pipeline, LNG or nuclar power project. Download the full article in the Climate and Energy Jourmal.  Read more

Challenges to Improving Energy Security Abound: Part 2

Energy Resources and Environmental Benefits

Since I sent this article to my editor, the world has changed. The Russo-Ukrainian War continues with no peace in sight. Part 2 of my article is on global energy security, which is being seriously being reevaluated in the US, Europe, United Kingdom, and every country in the world. My thoughts on global energy security may surprise some. However, I am a pragmatist at heart and believe that to secure our energy futures we must take energy security to the community level far from Think Tanks, the Washington DC Beltway and yes even Wall Street. Read more

Challenges to Improving Energy Security Abound: Part 1

Building electric transmission takes a decade

This article discusses the energy security of the US and whether the current trajectory of US policy will be able to achieve the latter. Energy security involves balancing the tradeoff between the 4As of energy security- availability, accessibility, affordability and acceptability. The current vision of achieving energy security puts high emphasis on "acceptability' and favors clean energy. The Biden Administration envisions siting large solar and wind farms, interstate electric transmission and battery storage. The main points that are elaborated in the paper are:

  • High-level policy objectives seem to be out of touch with many stakeholders and communities who oppose sizable renewable energy projects sited near their communities and on federal lands and waters.
  • The reality on the ground is that dduplicative federal and state environmental assessments, conflicts, opposition, and legal challenges will work to stifle any significant investment in renewable energy and energy transmission on federal lands and waters. 
  • Despite the challenges of transmission siting and cost allocation in transmission planning and long interconnection queues for wind and solar projects, the Biden Administration hopes to achieve its clean energy agenda. 

I take a contrary view. Smaller decentralized electric grids and microgrids closely aligned to host communities may find resolving issues and making the tradeoffs between the four As much easier.

Download the entire article published in the Climate & Energy Journal

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Physical and Financial Hedging of Natural Gas

Natural Gas and Oil Markets

Natural gas utilities and gas-fired power generators cannot afford to be caught in a green vortex and rely too much on intermittent renewable energy. Physical and financial hedging of natural gas continues to be important in managing risks and is required as countries continue to accelerate their decarbonization efforts. Such efforts are crucial to manage natural gas and price risks especially if prolonged water and wind droughts,  colder winters, and hotter summers continue to  limit renewable energy production in future years.

Decarbonization efforts should not only entail increasing the installed capacity of wind and solar, and battery storage. Decarbonization must also embrace carbon capture, storage, and utilization, blending hydrogen in natural gas grids. Also, the US, EU and China must accelerate efforts to reduce methane and carbon dioxide (CO2)in their oil and natural gas supply chains and from landfills, livestock farms, and other methane sources. Finally, the role that nuclear power can play in the transition must be considered by each country.

Some countries may want to establsih a Strategic Gas Reserve as a backstop to supplement the private sector's efforts to hedge price volatility, especially if governments continue to transition away from the use of coal power plants and continue to retire nuclear power plants. Download the entire article published in the Climate & Energy Journal

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Improving US Energy Security: Granting FERC Siting Authority over Interstate High Voltage Electric Transmission

The Biden Administration and the US Congress are giving serious consideration to granting the Federal Energy Regulatory Commission (FERC) the authority to site high voltage (HV) interstate electric transmission lines . FERC already has authority under the Natural Gas Act (NGA) to regulate the siting of and rates charged by interstate natural gas pipelines and storage facilities. Proponents of giving FERC such additional authority point to the extensive buildout of the natural gas pipeline system. These proponents believe that FERC could do the same with interstate HV electric transmission. While on the surface granting FERC such additional siting authority over HV electric transmission may appear logical, this author believes it is a big mistake—that US energy security would not improve, and even decline under such FERC authority. The main reason why this author is against transferring interstate electric transmission to FERC is the fact it would federalize all proposals, subject them to the National Environmental Policy Act (NEPA) and related delays, and ultimately give the States de facto veto power over the timing and the construction of these facilities. Such a move without some meaningful changes in existing laws, could likely provide a central venue to opponents of energy infrastructure that will prove administratively unwieldly for FERC and other agencies to manage. The result could be a longer and more litigious siting process with the distraction of NEPA and few projects ever being built. 

Download the entire arrticle published in the Climate & Energy Journal. Read more

All Eyes on FERC: Energy vs. Environment

Key Elements Needed in FERC’s Revised Pipeline Policy

FERC does not have the luxury to focus only on NEPA and issues dealing with GHG emissions, landowner and environmental justice (EJ) community issues. While important issues, interstate natural gas facilities are critical infrastructure. FERC’s decisions on new interstate natural gas facilities will have to equally consider energy security and resilience of the natural gas and the electric grids. Read more

Reimagining Hydropower and Green Hydrogen

Hydropower projects can produce green hydrogen

The US, European Union, and other countries that have set net-zero carbon emission targets and participate in the Paris Accord are placing big bets on wind and solar to produce green hydrogen (H2). Here in the US lawmakers and policy makers seem to have overlooked hydropower as a source of renewable energy even though it accounts for 52 percent of the nation’s renewable electricity generation and 7 percent of total electricity generation . For example, indigenous communities and environmental groups are opposed to hydropower because of its impacts on fish, wildlife, and water quality.

Many hydropower owners are taking a hard look at the economic value of their projects in light of climate change, aging infrastructure, increased operating costs due to environmental compliance, and evolving electricity markets. Many small hydropower projects are especially affected by the above factors since they provide only electric energy and not the peaking capacity and ancillary services valued by the electric grid. Nevertheless, these projects have value since a growing number now contain license conditions to reduce environmental impacts when they were initially built. In a previous column, this author also discussed a way for owners of “low impact hydropower” to fully monetize their project’s attributes by seeking renewable energy certificates (RECs).

This author now also suggests that hydropower can play a significant role in jumpstarting the production and distribution of green hydrogen (H2). However, this will require all hydropower owners and developers to reimagine how their projects will operate and diversify their revenue streams over the next 20 years. If hydropower projects can produce sufficient quantities of green H2, they could accelerate efforts to decarbonize natural gas by blending green H2 in the natural gas grid and help states meet their net-zero emissions. On November 23, 2020, Southern California Gas Co. and San Diego Gas and Electric announced the creation of a Hydrogen Blending Demonstration Program . This program is the first in California and the nation.

One of the biggest challenges with the hydropower industry has been its laser focus of trying to influence Congress and regulators on streamlining the siting process instead of reimagining a non-traditional role for hydropower outside of the electric grid. The National Hydropower Association (NHA) has influenced both Congress and the Federal Energy Regulatory Commission (FERC) to streamline its environmental and regulatory reviews to some degree. The NHA has had some success to date but is still short of what is expected by many hydropower owners and developers . For example, FERC has promulgated an expedited process for issuing original licenses for qualifying facilities at existing nonpower dams and for closed-loop pumped storage projects, pursuant to sections 3003 and 3004 of the America’s Water Infrastructure Act of 2018. NHA has also seen progress in extending the time to construct new hydropower projects and set a minimum FERC license term of 40 to 50 years instead of 30 to 50 years.

Despite the above progress, FERC’s regulatory reviews remain some of the most comprehensive and take years for staff to complete, despite the size of the hydropower project. Both small and large hydropower projects that were licensed or constructed prior to passage of the National Environmental Policy Act of 1969 (NEPA) are especially challenged by new environmental conditions included in new licenses and operating conditions. 


Comprehensive NEPA reviews and compliance with environmental laws during the life of a hydropower project are here to stay and are not likely to change. Despite being a form of renewable energy, many hydropower projects are lightning rods for public controversy and duplicative regulation by other federal and state agencies other than FERC. The controversy centers on competing use of rivers. Many indigenous communities and environmental groups and environmental agencies want to use water to restore anadromous fish runs and protect fish, wildlife, water quality, and recreation. In contrast, hydropower owners and other communities want to use the project for power generation, water supply, and flood control and other developmental uses, including the prevention of salt-water intrusion on ground water in coastal areas. Download the complete article in the Climate & Energy Journal. Read more

Comments on FERC's Certification of New Interstate Natural Gas Facilities

US Natural Gas Pipelines

Russo on Energy LLC (RoE) filed comments on FERC's Notice of Inquiry on whether, and if so how, it should revised its current policy on whether interstate gas facilities are in the public interest. RoE's views were based on its independent research and did not represent any of the current stakeholders in Docket No. PL18-1-000. RoE comments can be summarized as follows:

  1. FERC should not second guess the markets nor abandon precedent agreements entirely as a determination of need. Instead, the Commission should supplement its needs analysis with official comments from state energy agencies and public utility commissions, especially when affiliate companies are involved;
  2. FERC should use it new Office of Public Participation and existing Dispute Resolution Service to facilitate settlements among gas facility applicants and landowner, EJ communities and other stakeholders including state agencies;
  3. FERC should condition certificates to implement technologically feasible mitigation measures to reduce intended and unintended methane and CO2 emissions or require the development of such plans during the life of the project;
  4. FERC should increase oversight and enforcement of conditions to mitigate environmental impacts during construction and ensure restoration of land;
  5. FERC should require on the ground surveys to identify environmental justice communities and not rely solely on census data;
  6. FERC should use the 4 As of energy security (availability, accessibility, affordability and acceptability) as a framework to determine whether or not a project is in the public interest;
  7. FERC should revise it Pipeline Policy to communicate to interstate natural gas pipeline applicants that it values mitigation measures that reduce intended and unintended methane and CO2 emissions on proposed facilities; and
  8. FERC's revised policy statement should also communicate the natural gas and oil industry how it values decarbonization efforts being developed using Responsibly Sourced Gas, Renewable Natural Gas and Blending of Hydrogen in natural gas pipelines.

Download the official comments here. Read more

Rethinking Low Impact Hydropower and Renewable Energy Certificates

Low Impact Hydropower Project

Wind and solar projects along with their related renewable energy certificates RECs) are on the minds of energy generators, consumers and policy makers. This begs the question as to why hydropower and specifically low impact hydropower are not eligible to receive the same attention. A closer look at the issue reveals both the states and consumers have much to say about the technologies that qualify for RECs. In fact, low impact hydropower projects may qualify for RECs under some individual State Renewable Portfolio Standards (RPS) or the US Environ- mental Protection Agency’s (EPA) Green Power Partnership but not all.

This places the burden on a hydropower developer who believes that their project qualifies for a REC to either work with the relevant state agencies to determine the project’s eligibility and then with third-party validation organizations such as the Low Impact Hydropower Institute (LIHI) and the Center for Resource Solutions Green-e Standard (CRS)2 to be eligible to receive a REC. That may be difficult and expensive, because a state’s view of hydropower is based in part on past regulatory practices associated with the construction and operation of hydropower projects. Some states may understand this, but it may be difficult for them to make exceptions to existing rules and regulations even when a project’s operation changes and benefits environmental resources.

The process of obtaining RECs for a hydro- power project is complicated because the definition of “low impact hydropower” is not defined by federal law. In fact, many states and consumers automatically exclude hydropower because of its reputation as being threatening to the environment and aquatic life. In contrast, states and consumers readily embrace wind and solar as projects that would qualify for RECs even though the effects of wind farms on bird and bat populations and the large environmental land requirements of solar projects are well known. This author believes that rethinking the definition of low impact hydropower is long over- due. States and most consumers fail to recognize the significant changes in law and the Federal Energy Regulatory Commission’s (FERC) regulatory program and case law regarding US hydropower that have occurred since the passage of the National Environmental Policy Act (NEPA) of 1969. When these factors are considered, this author believes there are large numbers of hydropower projects that would qualify as “low impact” and ultimately qualify for RECs. If that occurred, hydropower could be recognized for its contribution in various state RPS programs and in the EPAs Green Power Partnership and play a larger role in the nation’s energy transition away from fossil fuel generation. This would benefit hydropower owners and companies wishing to decarbonize their organizations. Read the full article in the Climate and Energy Journal. Read more


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