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Justin Gundlach

Senior Attorney

Justin Gundlach joined Policy Integrity in April 2019. His work focuses on state-level energy and climate policy. He is the co-editor, along with Michael Burger, of Climate Change, Public Health, and the Law (Cambridge University Press, 2018), and the author of numerous articles, book chapters, white papers, and amicus briefs on legal and policy issues related to the impacts of energy use on the climate and of climate change on infrastructure and public health.

Before joining Policy Integrity, Justin was a member of the Policy Development team at the New York State Energy Research and Development Authority (NYSERDA), a Staff Attorney at the Sabin Center for Climate Change Law at Columbia Law School, a Staff Attorney and Clinical Teaching Fellow at Georgetown University Law Center’s environmental litigation clinic, and an associate at Crowell & Moring LLP. He received an L.L.M. with distinction from Georgetown University Law Center, a J.D. cum laude from NYU School of Law, an M.Sc. from the London School of Economics, and a B.A. magna cum laude from Wesleyan University.

Bar Admissions: State Bar of New York

Follow him on Twitter at @JMGinNYC, email him at, or call him at (212) 992-8167.



Harmonizing State Energy Utility Regulation and Climate Laws: A Case Study of New York (with Elizabeth Stein), 41 Energy Law Journal 211 (2020).
Building a New Grid Without New Legislation: A Path to Revitalizing Federal Transmission Authorities (with Avi Zevin, Sam Walsh & Isabel Carey):
  • Joint report with Columbia Center on Global Energy Policy.

  • 41 Ecology Law Quarterly (forthcoming 2021).

Climate Risks Are Becoming Legal Liabilities for the Energy Sector, 5 Nature Energy (February 2020).
Resilience Financing – Building Resilience to Natural Hazards and Accidents (with Cullen Howe), Real Estate Financing (LexisNexis 2019) (reprinted in California Law Reporter) (January 2020).
Microgrids and Resilience to Climate-Driven Impacts on Public Health (invited symposium contribution), 18 Houston Journal of Health Policy & Law 77 (2018).
DER Participation in Wholesale Markets: Lessons from the California ISO (with Romany Webb), 39 Energy Law Journal 47 (2018).
To Negotiate a Carbon Tax: a Map of Policy Interactions, Tradeoffs, and Risks, 43 Columbia Journal of Environmental Law 269 (2018).
Carbon Pricing in New York ISO Markets (with Romany Webb), 35 Pace Environmental Law Review 1 (2018).
Putting Green Infrastructure on Private Property in New York City, 28 Environmental Law in New York Newsletter 139 (Sept. 2017).
Integrating Climate Change Resilience Into HUD’s Disaster Recovery Program (with Channing Jones), 46 Environmental Law Reporter 10282 (2016).
Elec. Power Supply Ass’n v. FERC—The End of Wholesale Demand Response?, 42 Ecology Law Quarterly 699 (2015).
Books and book chapters
Section 115 in Practice, in Combating Climate Change with Section 115 of the Clean Air Act (Michael Burger ed., Elgar 2020).
Climate Change and Energy Transition Policies (with Michael Gerrard), in Oxford Handbook of Comparative Envtl. Law (J. Vinuales & E. Lees eds. 2019).
Climate Change, Public Health, and the Law (Michael Burger & Justin Gundlach, eds., 2018); authored: 
  • Chapter 6, The Built Environment (with Jennifer Klein)
  • Chapter 13, How Existing Environmental Laws Respond to Climate Change and Its Mitigation

Carbon Capture, Sequestration, and Utilization in the U.S. Climate Change Policy Context (with Michael Gerrard), in Carbon Capture and Sequestration: Emerging Legal & Regulatory Issues, 2nd ed. (R. Macrory & R. Stewart, eds. 2018).

Climate Engineering Research Governance (with Michael Burger), in Climate Engineering & the Law: Regulation & Liability for Solar Radiation Management & Carbon Dioxide Removal (Michael Gerrard & Tracy Hester eds. 2018). 

Court filings

New York v. HHS (S.D.N.Y 2019) (Conscience Protections Rule)

New York v. HHS (S.D.N.Y 2019)

West Virginia v. EPA, __ F.3d __ (D.C. Cir. 2017) (Clean Power Plan)

FERC v. Electric Power Supply Association, 136 S. Ct. 760 (2016)

King v. Burwell, 135 S. Ct. 475 (2014)

Utility Air Regulatory Group v. EPA, 134 S. Ct. 2427 (2014)

American Farm Bureau Federation v. EPA, 792 F.3d 281 (3d Cir. 2015)

EPA v. EME Homer City Generation, L.P., 134 S. Ct. 1584 (2014)


Carbon Pricing in Wholesale Energy Markets (Conference Brief) (May 2020)

Carbon Pricing in Wholesale Electricity Markets: An Economic and Legal Guide (March 2020)

Getting the Value of Distributed Energy Resources Right: Using a Societal Value Stack (December 2019)


NY Must Uproot Old Laws to Make Real Climate Progress, Law360 (December 17, 2020)

Utilities Should Be Required to Disclose Their Climate-Related Financial Risks, Utility Dive (December 15, 2020)

How New Jersey Can Still Meet Its Clean-Transportation Goals, NJ Spotlight (August 27, 2020)

This Is Not the Way to Move Beyond Net Metering, Utility Dive (June 18, 2020)

Should Fossil-Fuel Companies Bear Responsibility for the Damage Their Products Do to the Environment?, The Wall Street Journal (November 19, 2019)

We Need to Be Better Prepared for the Next Irma, Fortune (September 11, 2017)

U.S. Cities Know That Dropping The Clean Power Plan Is A Huge Mistake, Huffington Post (March 28, 2017)


Comments and Answer in Cricket Valley v. NYISO, FERC Docket No. EL21-7 (November 18, 2020)

Comments to Arizona Corporation Commission on Utilities' IRPs (October 15, 2020)

Comments to the New York PSC on Resource Adequacy (August 21, 2020)

Comments to New Jersey on Cost Test Straw Proposal (August 5, 2020)

Comments to Virginia on Developing an Energy Storage Rule (July 29, 2020)

Comments to FERC on Transmission Incentives (July 1, 2020)

Comments to FERC on NERA Net Metering Petition (June 19, 2020)

Comments to Colorado PUC on Valuing Distributed Energy Resources (June 5, 2020)

Comments to New Jersey BPU on Resource Adequacy Alternatives (May 20, 2020)

Comments to the Colorado Public Utilities Commission on Electricity Rule Changes (April 23, 2020)

Comments to FERC Supporting Petition for Technical Conference on Carbon Pricing (April 23, 2020)

Comments on the Transportation and Climate Initiative (February 28, 2020)

Comments on Connecticut’s Study of the Value of Distributed Energy Resources (February 14, 2020)

Comments to FERC on Offshore Wind Transmission (December 19, 2019)

Comments to the New York Public Service Commission on Resource Adequacy (submitted November 8, 2019)

Comments to Massachusetts on Clean Peak Energy Standards (October 30, 2019)

Comments on New Jersey’s Energy Master Plan (September 16, 2019)

Comments on Connecticut’s Proposed Value Categories for Distributed Energy Resources (August 21, 2019)

Comments to FDA on Sunscreen Products (June 27, 2019)

Comments to Iowa Utilities Board on Energy Efficiency Program Benefits (June 5, 2019)

Comments on DOE’s “Grid Resiliency Pricing Rule” (October 18, 2017)

Comments on Review of Marine Protected Areas Pursuant to Exec. Order 13795 (with Jessica Wentz, July 25, 2017)

Comments on the Draft Nationwide Programmatic EIS for the National Flood Insurance Program (with Jessica Wentz, June 1, 2017)

Comments on FERC’s Notice of Intent to Prepare an Environmental Impact Statement for the Planned Alaska LNG Project (November 12, 2015)

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