Recent Projects

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.

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.

We 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.

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.

In a recent presentation, the New York Independent System Operator (NYISO) posed key questions related to potential buyer-side mitigation reforms. We submitted comments that provide three recommendations to NYISO.

The New Jersey Board of Public Utilities (BPU) released a straw proposal for its Solar Successor Program. We submitted comments addressing a question about solar projects' potential benefits to environmental justice (EJ) communities. Our comments encourage BPU to consider the inclusion of an environmental justice adder and reommend that BPU explore an adder that would deliver material benefits to EJ communities. 

The Department of Energy proposed revisions to its procedures and policies for considering new energy conservation standards across a range of consumer products and commercial equipment. We submitted comments offering support for the proposed revisions and making additional recommendations. Our recommendations include weighing a full range of environmental and consumer effects, incorporating the consideration of distributional justice, and reviewing the selection of discount rates.