Comments of Colin R. Hagan Submitted to the U.S. Senate Committee on Energy and Natural Resources in Response to the ‘White Paper on a Clean Energy Standard’

These comments respond specifically to a question raised in the U.S. Senate Committee on Energy and Natural Resources’ “White Paper on a Clean Energy Standard.” These comments argue that the Committee should consider lifecycle greenhouse gas analysis as one factor in determining whether an energy resource, or a specific project, is a “clean energy” resource for the purposes of a clean energy standard. Lifecycle analysis is increasingly recognized as a necessary assessment for understanding the full greenhouse gas consequences of generating electricity, or producing transportation fuels, with a particular resource. Applying a lifecycle analysis in a clean energy standard will help ensure that a clean energy mandate maximizes greenhouse gas reductions. In addition, a lifecycle analysis can help identify cost-effective opportunities for reducing emissions from new energy projects. These comments do not provide a full assessment or recommendation for how to incorporate lifecycle analysis into a clean energy standard. Nor do these comments recommend the inclusion or exclusion of any resources in a clean energy standard. Rather, these comments merely highlight the importance of including a lifecycle assessment of greenhouse gases in determining whether a resource qualifies as a “clean energy” resource.