Recent Projects

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. 

The Maryland Public Service Commission requested input on its working group's energy storage report. We submitted comments in support of several of the working group's recommendations. We also encourage the Commission to apply the same principles that inform the report to assess the net emissions impacts of energy storage installations.

The New York Public Service Commission requested input on its Staff Gas System Planning Process Proposal. We submitted comments encouraging the Commission to add several minor requirements and directly address the legal tensions and ambigious policies that make planning decisions more challenging.

The Federal Energy Regulatory Commission (FERC) requested input on the expanded minimum offer price rule (Expanded MOPR) in the PJM capacity market, as well as prospective alternative approaches that could replace PJM's Expanded MOPR. We submitted comments addressing the questions posed while drawing attention to reforms that FERC should undertake.