Recent Projects

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.

New York's electric utilities have developed a coordinated grid planning process and an updated approach to analyzing the benefits and costs of infrastructure investments. Policy Integrity filed comments urging the Commission to recognize that compliance with the Climate Act in relation to grid planning requires, at the very least, consideration for planning decisions' impacts of global and local pollutants.

In 2018, New Jersey established a Zero-Emissions Credits (ZECs) program, which provides subsidies to the state’s nuclear power plants for reducing carbon emissions in the energy sector. Our amicus brief explains how the Social Cost of Carbon is the best available estimate for valuing harms caused by carbon dioxide emissions. We also argue that the ZECs program should account for the benefits of avoided emissions both inside and outside of New Jersey.

Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on it proposed energy efficiency standard for general service lamps (i.e. lightbulbs). Our comments applaud DOE for using the social cost of greenhouse gases (SC-GHGs) in analyzing the proposed rule, but encourage the agency to expand upon its rationale for adopting a global damages valuation and for the range of discount rates it applies to climate effects. We further recommend that DOE disclose the SC-GHG estimates that it applies after 2050.

Our comments recommend that FERC make significant changes to enhance the transmission planning and cost allocation processes -- changes that address barriers to development of regional and interregional transmission that would interconnect and integrate far-flung but low-cost renewable resources. We argue for using a nationally uniform, forward-looking cost-benefit analysis to guide project selection and encourage the Commission to consider prescribing cost allocations that distribute the costs associated with societal benefits and public goods as broadly as possible.

In reply comments to comments submitted by other parties, we clarify that FERC has authority to define the benefits of transmission capacity and to guide the allocation of transmission project costs among beneficiaries.

Policy Integrity signed on to comments filed with the Colorado Public Utilities Commission (PUC) by Western Resource Advocates and the Western Grid Group. These comments sum up the key arguments presented in the long-running docket in which the PUC has considered questions about participation in a competitive wholesale market. The comments organize the points made in support of Colorado opting to join a new western Regional Transmission Organization (likely an expanded version of California's ISO+EIM) instead of joining SPP to the east or establishing its own Colorado-only RTO.

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.

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.