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Recent Projects

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  • Comments on New York PSC’s Grid Planning Process

    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.

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  • Carbon Trading for New York City’s Building Sector Cover

    Carbon Trading for New York City’s Building Sector

    Report of the Local Law 97 Carbon Trading Study Group to the New York City Mayor’s Office of Climate & Sustainability

    NYU researchers assessed whether New York City should adopt a carbon trading program for its buildings pursuant to its landmark climate law, Local Law 97 of 2019. The study offered two proposals for trading programs, both of which would benefit the City as a whole, and environmental justice communities in particular, and found that both proposals would lead to deeper GHG reductions and lower the cost of complying with LL97.

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  • 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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  • Comments to NYISO on Buyer-Side Mitigation Reforms

    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.

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  • Comments to New York PSC on Gas Planning Procedures

    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.

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  • Comments on New York PSC’s Initial Report on Power Grid Study

    The New York Public Service Commission (PSC) requested input on its initial report on the New York Power Grid Study. Our comments recommend steps the PSC can take to not only achieve emissions reduction goals, but also give appropriate priority to environmental justice.

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  • Comments to FERC on Clean Resources’ Participation in NYISO’s Capacity Market

    Complainants in an ongoing proceeding ask that the Federal Energy Regulatory Commission (FERC) make changes to the New York Independent System Operator (NYISO)'s capacity market that would impose offer floors on all capacity market bids by state-supported renewables. We submitted comments showing why the complaint's arguments and evidence fall short of the legal standards required for FERC to make the findings and grant the relief requested.

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  • Comments to New York DEC on the Value of Carbon

    New York State's Department of Environmental Conservation (DEC) has adopted a damage-cost approach to valuing carbon dioxide pollution. We submitted comments on the DEC's draft guidance supporting the policy. Our comments also raise points about the appropriate use of discount rates, calculating damages for other greenhouse gases, inclusion of co-benefits in analysis, and further considerations for a marginal abatement cost approach.

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  • Comments to the New York PSC on Resource Adequacy

    The Brattle Group developed a resource adequacy scenario analysis for the New York Public Service Commission (PSC), which is considering how to best meet its electricity generating capacity and resource adequacy needs. We submitted comments encouraging the PSC to consider several questions that Brattle’s analysis does not examine in depth.

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  • Our Work on State Zero-Emission Credits Programs

    Several states have determined that ensuring the viability of zero-emission electricity generation from nuclear power is critical to mitigating the impacts of climate change especially in the short term while states work to meet aggressive new clean energy goals. Through comments and amicus briefs, we’ve been involved in those efforts in both New York and New Jersey.

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