Recent Projects

The Connecticut Public Utilities Regulatory Authority (PURA) issued a straw program design for electric storage. We submitted comments that support PURA's efforts to make energy storage part of its overarching decarbonization agenda and provide feedback. It is important, as we explain, that PURA take into account the potential emissions consequences of energy storage operations in designing its performance-based incentive.

After the Department of Energy published a supplemental environmental impact statement claiming that exporting liquefied natural gas from a proposed Alaska terminal would decrease greenhouse gas emissions, we submitted comments challenging the Department’s methodology and assumptions. In particular, our comment letter explains that the Department’s analysis unreasonably assumes that the Project would merely displace existing exports from Gulf Coast facilities, and thus overlooks the inevitable economic reality that the Project will increase total natural gas supply and consumption. As our comment letter explains, courts have rejected this “perfect substitution” assumption in related contexts. Moreover, our letter explains that the Department’s lifecycle analysis insufficiently considers the choice of destination countries and is inconsistent with the agency’s analysis of economic impacts.

Last July, PJM Interconnection (the electricity grid operator for 13 states and the District of Columbia) submitted revisions to its Minimum Offer Price Rule (MOPR) for its capacity market to the Federal Energy Regulatory Commission (FERC) for approval. The new rule (the “Focused MOPR”) would remove an artificial barrier to market entry for resources that receive such externality payments under state climate and clean energy policies. Policy Integrity filed an amicus brief in support of FERC and PJM’s Focused MOPR explaining why the rule is welfare-enhancing and would not threaten reliability.

The Climate Leadership and Community Protection Act (CLCPA or the Act) committed New York to an ambitious set of changes across all sectors of the economy. The development of a Scoping Plan, as called for by the Act, will help steer New York's agencies--and legislature--as they initiate those changes. Policy Integrity's comments focus on the Electricity and Gas System Transition chapters of the Draft Scoping Plan. In addition to voicing support for several of the measures listed in that plan, those comments encourage adoption of further measures in a final version of the plan. Those additional measures would support greater coordination of electricity sector stakeholders' decisions and would create a greater degree of certainty about the nature and pace of gas system transition.

Together with the Environmental Defense Fund and Professor Madison Condon of Boston University School of Law, we submitted three sets of comments to the Securities and Exchange Commission (SEC) in support of its Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (Proposed Rule). The Proposed Rule would require publicly traded companies to disclose important information about the extent to which climate change is already affecting their financial performance, their approach to climate-related risk management, their climate-relevant governance structures, and their greenhouse gas emissions, which serve as a proxy for exposure to risk from policy- and market-driven shifts to a clean-energy economy.