Comments to DOE on Conservation Standards for Furnaces and Water Heaters
In August 2021, DOE proposed to return to holding less-efficient gas furnaces to the same standard as other gas furnaces. We filed comments supporting the proposal, while cautioning DOE against making unnecessary statements that might hinder its ability in the future to set standards that would encourage consumers to switch from gas-fired appliances to electric appliances.
Shaping Virginia’s Energy Storage
Virginia recently adopted aggressive decarbonization legislation, which recognized that energy storage has an important role to play in decarbonizing the power sector. The Virginia Energy Storage Task Force (VESTF) was convened to help guide the deployment of energy storage resources. Senior Attorney Justin Gundlach served on the task force, and VESTF's final report drew extensively on Policy Integrity's research, including its reports on energy storage policy, valuing DERs, and DERs' emissions reduction potential.
Comments to FERC on Climate Risks, Reliability, and Resilience
The Federal Energy Regulatory Commission requested responses to a number of questions on the effects of climate change and electric system reliability. In April 2021, we submitted comments highlighting opportunities to improve reliability and resilience by adjusting approaches the Commission and others take to planning, investing in, and operating grid components.
Then FERC, following a technical conference over the summer, requested further comments on a specific series of questions. In September 2021, we submitted joint comments describing process options and resources for conducting climate resilience planning, and emphasized how accounting for climate impacts is relevant to consumer costs.
Comments to Michigan PSC on Extreme Weather Planning
In the aftermath of summer storms that resulted in widespread and prolonged power outages, Michigan's Public Service Commission requested comments on whether utilities should continue to rely exclusively on historical data when planning for extreme events. In comments filed jointly with the Sabin Center for Climate Change Law at Columbia Law School, and the Initiative for Climate Risk and Resilience Law, Policy Integrity suggested processes and tools that the Commission should direct utilities to use to identify and mitigate vulnerabilities to the impacts of extreme weather and climate change impacts more generally.
Comments to FERC on Joint Federal-State Task Force on Transmission
We submitted comments to FERC today providing suggested topics for the first meeting of the joint federal-state task force on transmission. Our comments respond to a request for topics related to barriers inhibiting more efficient and effective transmission planning and deployment. We identify two barriers that the task force should discuss -- jurisdictional issues related to transmission siting and the lack of a standardized cost benefit analysis rubric for transmission projects.
Building a New Grid without New Legislation: A Path to Revitalizing Federal Transmission Authorities
Published Ecology Law Quarterly
In the absence of legislation, critical long-distance transmission can be developed by applying existing federal legal authorities. A number of important regulatory and commercial measures have been proposed, including streamlining transmission planning, upgrading existing transmission system components, putting transmission lines underground, and using existing rights-of-way from highways and railroads. Even if these solutions are adopted, however, state siting requirements may prove an important obstacle to developing an efficient, national transmission grid. So, this paper examines legal authorities already available to the Department of Energy and the Federal Energy Regulatory Commission to develop the interstate transmission capacity crucial to the energy transition.
Comments to FERC on Evangeline Pass Expansion ProjectWe filed a comment letter with the Federal Energy Regulatory Commission (FERC) regarding their continued failures to meaningfully assess the climate impacts of natural gas infrastructure projects, this time regarding the Evangeline Pass Expansion Project EIS. Two companies have requested authorization to construct and operate a new pipeline, compressor stations and meter stations in Louisiana and Mississippi, which will be used to transport up to 1,100,000 dekatherms per day to an LNG facility for export.
Modeling Strategic Objectives and Behavior in the Transition of the Energy Sector to Inform Policymaking
in The Electricity Journal
The typical starting point and centerpiece of energy decarbonization is the electric power sector, a large direct GHG emitter. Published in The Electricity Journal, this paper explores what the modeling community should do to inform this transition, including expanding energy market datasets and designing models that incorporate multiple objectives and manifold actors behaving strategically in a framework consisting of large uncertainty, while accounting for the physics of power systems.
Climate and Power System Reliability in the Aftermath of the Texas Blackouts
The February 2021 blackout in Texas underscored the importance of reliable and resilient power systems. This article discusses the roles of regulators, markets, fuel and generation supply chains, and interdependent infrastructures, and finds that they need to be reconsidered and redefined to successfully meet the future challenges of increased electrification and severe weather
Comments to New York PSC on Climate Change Vulnerability Assessments
We submitted comments to the New York Public Service Commission to voice our support for a petition concerning the impacts of climate change on utility infrastructure. Our comments emphasize that it is imperative for public utilities to identify and assess the risks that climate change poses to their assets and operations.
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