Recent Projects

The New York Independent System Operator (NYISO) has appointed Policy Integrity’s Executive Director, Dr. Burçin Ünel, to serve on its Environmental Advisory Council. The Council provides NYISO with information, analysis, and expert perspectives on state and federal environmental policies to help it better achieve its mission of maintaining reliability of the bulk electric system and administering competitive wholesale electricity markets. In her role on the Council, Dr. Ünel will use her expertise in utility regulation and energy policy to help NYISO build and maintain New York's “grid of the future.”

Together with Resources for the Future, we submitted comments to the New York Public Service Commission in response to questions posed by the Commission about addressing barriers to medium- and heavy-duty electric vehicle charging. Our comments focus on the possibility for managed charging to reduce infrastructure needs and on additional considerations to optimize emissions outcomes. Our comments are centered around depot charging and draw on research that examines fleet charging needs in a depot setting.

We submitted recommendations to the New York Public Service Commission regarding New York’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage, a document that analyzes the need to increase New York’s storage target to 6 GW and the barriers to storage deployment, and provides policy recommendations to help the state achieve 6GW of storage deployment by 2030.

Energy storage can play an important role in a transition to clean energy, but only if it’s deployed within an effective policy framework. The Connecticut Public Utility Regulatory Authority (PURA) adopted our recommendations to target its energy storage incentives to areas with the highest differential between the highest and lowest marginal emissions rates so batteries could ultimately lead to reductions in emissions. In addition, PURA directed the Connecticut Green Bank to review our comments when setting the scope of the program's marketing plan.

The Texas Public Utility Commission (PUCT) requested public input as part of an ongoing effort to ensure the reliability of its wholesale electricity market design following Winter Storm Uri. We submitted comments on how the PUCT can achieve its reliability goals in a manner that ensures just and reasonable rates for consumers. For any new mechanism it may deem necessary, we encouraged the PUCT to choose a design that accords with economic principles. Such a design would compensate both dispatchable and non-dispatchable resources according to their reliability value, include an efficient penalty structure for non-performance of generation units, reduce uncertainty for market participants, and mitigate market power exercise.

Together with Harvard’s Electricity Law Initiative, we prepared a policy brief and supplemental comments defending the Federal Energy Regulatory Commission’s (FERC) proposed rule on transmission planning reform from arguments that the proposal would trigger the major questions doctrine. We review previous transmission planning regulations and orders by FERC to explain that the major questions doctrine does not apply because the proposed rule is neither unheralded nor transformative.