Recent Projects

On May 13, 2024, FERC issued Order 1920, a landmark rule to improve regional transmission planning and cost allocation processes. The Order could ease the process of expanding electric transmission, helping integrate much more renewable energy to the U.S. grid. We submitted four rounds of comments in this proceeding: at the advanced notice of proposed rulemaking stage, then on the proposal, and then two sets of supplemental comments.  For several key features of the final rule, FERC adopted our recommendations.

On April 30, 2024, Senators Markey, Sanders, Warren, and Whitehouse sent a letter to ISO-NE President and CEO Gordon van Welie urging the independent system operator to improve its governance policies, proactively plan for new transmission, and ensure fair access to markets for clean energy technologies. The letter advocated for several changes that Policy Integrity has pushed in the past, including increasing opportunities for community participation in energy policy decisions and pursuing longer-term, holistic transmission planning. On the latter point, the letter cited our December 2023 report that advocated for more proactive transmission planning on the part of energy decisionmakers.

On April 25, 2024, the Department of Energy (DOE) released its final rule under 16 U.S.C. § 824p(h) to expedite the federal authorization of transmission projects. We commented in support of the proposal, including DOE's proposed requirement that project proponents describe how the transmission project would affect power-system greenhouse gas (GHG) emissions. In the final rule, DOE retained the requirement to describe power-system GHG impacts and, in response to our recommendation, clarified that the ambiguous language in the proposal does require project proponents to estimate non-power-system GHG emissions and power-system emissions of local air pollutants. 

In May 2023, the Environmental Protection Agency (EPA) proposed a package of regulations to limit greenhouse gas emissions from fossil fuel-fired power plants under Section 111 of the Clean Air Act. EPA subsequently issued a supplemental notice of proposed rulemaking, re-opening its comment period and soliciting comment on whether to include additional mechanisms to address potential reliability issues. In these comments, we explain why EPA has engaged in reasoned rulemaking and developed a robust administrative record comporting with its mandate to reduce power sector pollution. It remains the Federal Energy Regulatory Commission’s (FERC’s) responsibility to ensure reliable bulk-power system (BPS) operations and to use its corresponding tools to address the wider reliability challenges of the clean energy transition, in coordination with other reliability-related entities.

Policy Integrity submitted comments to FERC in support of American Clean Power Association’s petition for a technical conference on capacity accreditation. Holding a technical conference would be appropriate because accurate accreditation is becoming increasingly difficult as grids accommodate rapidly changing resource mixes with varying energy and reliability attributes, public policy constraints, and increasing/unprecedented extreme weather events. Moreover, accreditation has become more consequential, as capacity market revenues have grown to a significant share of total market payments. We included several questions that would merit discussion at the technical conference.