American Clean Skies Foundation

Public Policy

The American Clean Skies Foundation is a thought leader in our nation’s energy policy debates. ACSF regularly comments on regulations proposed by federal agencies and publicly engages government decision makers.

ACSF provides information to public policy leaders from a research and education perspective. We think through how regulations and other government action should be structured to meet our energy needs by emphasizing renewable energy sources and clean domestic natural gas.

ACSF recently has contributed public comments to the Environmental Protection Agency (EPA), the Federal Energy Regulatory Commission (FERC) and the Department of Energy (DOE):

We responded to EPA’s request for comment in support of its proposal to tighten National Ambient Air Quality Standards by reducing the amount of sulfur dioxide emissions, which causes ground level ozone and is hazardous to health. See our comments on the proposed change to the NAAQS here. ACSF will engage EPA on other air emissions, water and coal waste issues, as EPA formally announces its proposals in these areas.

We have explained to FERC, in their request for comment, how its recent proposal to further promote demand response, i.e. energy conservation, will have certain unintended consequences that work against our march toward cleaner sources of electric power. Click to see our commentson FERC energy conservation proposal. In the future, we expect to provide additional information to FERC on how our nation’s electricity dispatch rules, i.e. our rules for determining which energy sources supply our electricity, work against our clean energy goals.

In response to a recent DOE study on potential problems to our system of transmitting energy sources in the generation of electric power, we have asked DOE to better consider the role of natural gas in complementing renewables, and as a cleaner alternative to coal. See our comments to the DOE here. We will continue to press DOE and other entities that plan for our energy future to seek solutions that are cleaner, greener and more secure.

Climate Change Legislation

Because natural gas can generate electricity with 50% less CO₂ than coal, the expanded use of natural gas could be a "game changer" for U.S. climate action.

However, the cap-and-trade bills now before the Congress do not give priority to increasing the power sector's use of natural gas. We think that is a mistake and have developed a natgas incentive program that would address this shortcoming.

This program would enable Congress to accelerate CO₂ emission reductions from capped emitters by awarding additional emission rights to parties that use natural gas in place of a higher carbon fuel. One ton of emission credits would be awarded for every net ton of CO₂ emission reductions attributable to the substitution of natural gas, as compared to business as usual.

For more details about this cap-and-trade based incentive program, see this two page summary. Several examples of how capped entities would earn emission credits for using natural gas can be found here.

The merits of using more natural gas to help the country meet the environmental objectives set by climate change legislation have been endorsed by the Center for American Progress, the WorldWatch Institute and the Executive Director of the Sierra Club, among others. The specific natgas incentive program developed by the Foundation has also won the support of America’s Natural Gas Alliance and the Natural Gas Supply Association.

Managing NatGas Price Volatility

ACSF and the National Commission on Energy Policy (NCEP) are co-sponsoring a 16-month Task Force to develop new government and private sector options for managing natgas price volatility.

America’s growing natural gas resource base is now widely recognized. Yet, the development of these resources, especially unconventional shale gas "plays", will depend on sustained long term demand from end-users at prices that are sufficient to cover upstream production and transport costs. Whether or not this demand will be forthcoming – and at a sufficient price level – is now the subject of considerable debate.

North American markets for natural gas have historically seen periods of substantial price escalation and volatility, and these price swings have tended to destroy industrial demand followed, in turn, by large cut backs in production and E&P activities.

Against this background, a full understanding of the factors underlying market volatility for this commodity and the best options available for managing it -- both from a regulatory standpoint and through commercial, private sector activities – takes on a new importance. Indeed, better tools for managing price volatility may be an essential prerequisite for recognizing the economic promise of America’s new natgas resource base as well as the potential public policy benefits.

ACSF and NCEP are assembling a task force of leading stakeholders to examine these issues through three sets of white papers and broad-based, but invitation-only, workshops. The papers will cover: (1) economic and legal background; (2) private sector options for managing volatility; and (3) public policy options. Based on the papers and workshop dialogues, the Foundation and NCEP plan to prepare a final, book-length report and recommendations for government action and private sector initiatives. This work will then be presented at a day long public conference.

Our current schedule contemplates workshops in March, June, and October of 2010, with a final report publicly released in January 2011. Up to eight corporate co-sponsors will be accepted for this project, and some sponsorship opportunities are still available. Please contact the Foundation's CEO if you are interested.

MIT Future of Gas Study

Two years in the making, this breakthrough study by Massachusetts Institute of Technology scientists calls for the widespread use of natural gas for electricity generation and transportation.

The study takes a hard look at the promise and problems of natural gas – and its finding will contribute to the science underpinning policy decisions. The interim report, released June 25, will influence climate and energy bills now taking shape in Congress. The study coincides with President Obama’s call for using natural gas as a bridge fuel to accelerate America's move toward clean energy as well as with congressional efforts to curb greenhouse gases. The report says that even a modest shift from coal to natural gas at power plants would achieve a reduction in carbon emissions equal to half of the goal the president set in Copenhagen for 2020.

This study, which will be completed in the Summer of 2010, will augment MIT's prior reports on The Future of Coal (2007) and The Future of Nuclear Power (2003).

“There is no longer any doubt that we have the capacity to repower our electricity sector and move away from dirtier fuels,” said Gregory C. Staple, CEO of American Clean Skies Foundation, one of the study’s sponsors. “The MIT report demonstrates that. It’s now up to the Administration and Congress to ensure that any new energy legislation contains a robust natural gas title that reflects these findings.

"At a minimum," Staple said, "a new energy bill should adopt stricter greenhouse gas emission standards for existing power plants and set a timetable for phasing out the least efficient and dirtiest coal-fired power plants, roughly 20% to 25% of generating units. The power from these plants should be replaced with electricity derived from natural gas and renewable fuels."

The study is being directed by Dr. Ernest Moniz, Director of the MIT Energy Initiative, and Melanie Kenderdine, Associate Director.

The work of the MIT study team is also overseen by an independent Advisory Board whose members include:

Copenhagen Forum

The Foundation, together with the Worldwatch Institute and the UN Foundation, brought natural gas to the center of climate policy discussions in Copenhagen during the landmark UN negotiations for a new global climate change treaty in December 2009. These negotiations are formally known as the 15th Conference of the Parties (COP-15) to the UN Convention on Climate Change (UNFCC). The initiative will highlight the potential of natural gas to contribute to near- and medium-term emission reductions.

On December 12, ACSF and its co-sponsors hosted a major Side Event at the Copenhagen headquarters of the Danish Society of Engineers (known as the IDA). At the Side Event, ACSF released a comprehensive new working paper entitled "North America's New Natural Gas Resources and their Potential Impact on Energy and Climate Security." Download the introduction (PDF, 340kb).

Copies can be obtained by request from the Foundation. See the media advisory and agenda for more details about this event.

ACSF's Copenhagen event was also covered by the Sopris Foundation. See their interview with CEO Gregory C. Staple.

Also at the event, ACSF and RPSEA (Research Partnership to Secure Energy for America) jointly released the following report "Worldwide Gas Shales and Unconventional Gas: A Status Report." The report was commissioned from Advanced Resources International, Inc. and written by ARI's President, Vello A. Kuuskraa.