Menu
Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in New York
  • 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.

    Read more

  • 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.

    Read more

  • 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.

    Read more

  • 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 We submitted comments on the DEC's draft guidance supporting the policy.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.

    Read more

  • 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.

    Read more

  • 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.

    Read more

  • Comments to the New York Public Service Commission on Resource Adequacy

    We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.

    Read more

  • Court Upholds New York’s Zero-Emissions Credit Program for Nuclear Power

    The Albany County Supreme Court rejected a challenge to New York’s Zero-Emissions Credit (ZEC) program, which pays nuclear power plants for the value of avoided carbon emissions. The legal challenge focused largely on the state’s decision to use the Interagency Working Group’s Social Cost of Carbon (SCC) to value emissions.

    Read more

  • Comments to FERC on NYISO and Energy Storage Resources

    A new wholesale energy market policy proposal in New York could undermine market efficiency by limiting the compensation available for energy storage resources. The New York Independent System Operator (NYISO) recently submitted changes to its market rules to encourage energy storage, as required by an order from the Federal Energy Regulatory Commission (Order No. 841). The filing prevents energy storage resources from participating in the wholesale markets if they also participate in retail compensation programs. We submitted comments explaining how this participation barrier is inconsistent with FERC’s requirements and should be changed.

    Read more

  • Comments on New York State Energy Storage Roadmap

    In June 2018, the New York State Department of Public Service and the New York State Energy Research and Development Authority released the New York State Energy Storage Roadmap, outlining a series of recommended approaches to achieve Governor Cuomo’s statewide energy storage target of 1,500 MW by 2025. Our comments, based on our Managing the Future of Energy Storage report, generally support the overall approach to reward energy storage systems for all the values they can bring to the electric system, to allow dual participation in both wholesale and retail electricity markets, and to improve price signals to maximize the benefits of energy storage systems.

    Read more