Justin Gundlach Profile picture
Senior Attorney @PolicyIntegrity. Formerly @NYSERDA, @SabinCenter. But here I just speak for myself.
Feb 15, 2021 10 tweets 5 min read
@NYSDPS filed its gas system planning whitepaper on Friday (stakeholders've been waiting for months). It aims to avert gas moratoria & start aligning the gas system with NY’s climate law, the CLCPA. documents.dps.ny.gov/public/MatterM…

This 🧵 flags some key items, including a basic problem. (Looking for an intro to this corner of New York’s climate/energy/utility policy? Check out this webinar policyintegrity.org/news/event/whe… and/or Parts I and II of this article eba-net.org/assets/1/6/9_-….)
Feb 12, 2021 8 tweets 2 min read
There are some very big points about the politics of electrification to take from this very small story.

🧵 commonwealthmagazine.org/health/baker-a… The kerfuffle roots in the (flawed! it-doesn't-have-to-be-this-way!) two-part-premise that

(a) the key barrier to electrification is individuals' and businesses' preferences, and

(b) that the path forward will involve govt defeating those preferences somehow.
Sep 30, 2020 160 tweets 27 min read
Today's FERC technical conference on carbon pricing is about to start. ferc.gov/news-events/ev… It's going to be ~9 hours(!) of focused discussion. So, basically the opposite of last night's debate. I'll be tweeting about it in this thread... If you want to see the agenda or panelists' prepared remarks, FERC has posted everything on the same page as the webinar link.

And if you'd like to start with the latest, definitive report on carbon pricing in RTOs, here's the link for you: policyintegrity.org/files/publicat…
Aug 10, 2020 6 tweets 2 min read
Power outages, microgrids, climate adaptation, and how good climate laws and grant programs can help put solutions in the right places (and not the wrong ones!); a modest five-part 🧵 with a focus on New Jersey. 1/ After Superstorm Sandy, CT, NY & NJ all adopted grant pgms to facilitate microgrid development for public purposes. Key goal: make critical facilities (hospitals, fire, police, shelters) resilient to long-duration outages. climatecentral.org/news/microgrid…
Aug 7, 2020 13 tweets 5 min read
Short 🧵 about including avoided emissions (greenhouse and local pollutants) in valuation of the costs and benefits of energy efficiency in New Jersey, which just asked for comments on a proposed, interim New Jersey Cost Test. nj.gov/bpu/pdf/NJ%20C… Image A 2018 law directs NJ's Board of Public Utilities to create energy efficiency and peak demand reduction programs that will help ratepayers save money. The law requires those programs to be net-beneficial. Image
Jul 10, 2020 7 tweets 4 min read
Vote Solar just reached a settlement with Duke Energy Carolinas. One winning item in there is a requirement that Duke undertake “climate-resilience planning,” ie, a climate change vulnerability assessment + plans to address identified vulnerabilities.
starw1.ncuc.net/NCUC/ViewFile.… Image This is a very good thing! By examining how expected changes in temperature, humidity, sea level, and coastal storms will affect Duke’s assets and operations, Duke will identify ways to better ensure reliability and avoid costly damages. Better service, less ratepayer money.
Jul 2, 2020 15 tweets 6 min read
@PolicyIntegrity just filed comments on FERC’s proposed transmission incentives rule. policyintegrity.org/documents/Poli…

Niche 🧵 on market failures, regulatory incentives & electricity transmission.

Context: Wow do we need more & better transmission infrastrctr. latimes.com/environment/st… Three key points of background:

1/ The Energy Policy Act of 2005 encouraged transmission development (but stopped way short of making electricity transmission development as speedy as gas pipeline development).
Jun 24, 2020 7 tweets 2 min read
Minnesota is suing Big Oil.

Here's the complaint: ag.state.mn.us/Office/Communi…

It's a legal document, but it's also a thorough history, complete with primary source documents. Image This case is notable in at least 3 respects.

1) Till now, only cities (not states) have sued over fossil fuel sales alleging direct harms to citizens & consumers.

2) This suit is all about fraud, a somewhat new climate litigation angle.

3) Minnesota seeks flexible remedies.
Jun 19, 2020 14 tweets 4 min read
New York’s Dept of Public Service published a whitepaper yesterday. For people who have been paying attention to NY energy/climate policy and wondering how the state is going to square the circle of decarbonizing the downstate region, it’s a humdinger.
urldefense.proofpoint.com/v2/url?u=http-… There’s a lot in there, but this 🧵 is focused on the Tier 4 REC (part II.c.3 of the whitepaper).

I have a theory—please tell me where you think it goes wrong. Image
Jun 16, 2020 7 tweets 2 min read
What did @PolicyIntegrity bring to the NERA gunfight?

Some "wholly original" arguments!

Now that you're intrigued, here's a 🧵 NERA's petition relies on Ashley Brown's report for its facts. Brown has argued before state commissions for years. You can tell, b/c his report says that *retail rate reform* (which FERC can't do!) is the best solution to what he calls the "perverse effects" of net metering.
Apr 21, 2020 4 tweets 1 min read
This Administration, whose willful ignorance & instinct for political opportunism ueber alles in the face of pandemic has gotten a lot of people killed is now opening up a full barrage on the regulatory state. washingtonpost.com/business/2020/… If Covid can teach America anything, it's that expertise & sound government save lives, & make them better. But this Admin doesn't learn, & we're 7 months from the election +3 more (in the best case scenario) of what might be the most terrifying lame duck session in history.
Apr 15, 2020 9 tweets 3 min read
@Sammy_Roth wrote an excellent piece last week about how the last crash prompted the fed govt to spend big on clean energy to great effect. latimes.com/environment/st…

Here's a related thread about the renewables siting law New York adopted just when covid-19 started to hit hard... That law establishes a new approach to siting renewables (good description here: natlawreview.com/article/new-yo…). It’s a very big deal--for energy policy *and* for post-covid economic recovery.
Mar 24, 2020 11 tweets 5 min read
Want a break from pandemic? (An intellectual one. Best I can do.)

Here’s a thread about a federal district court’s hot-off-the-presses decision in the CLF v. Exxon case.

E&E's (paywalled) article: eenews.net/climatewire/20…
Court's decision: eenews.net/assets/2020/03…
1/10 It's a “climate” case, but it doesn’t focus on impacts of emitting activity. Instead, it’s about whether Exxon is addressing the impacts of climate change *on* its coastal facility in Everett, Mass. (It’s in the 3rd category of cases discussed here )
2/10
Mar 4, 2020 7 tweets 2 min read
Quick thread on NYPIRG's timely proposal for making New York's progress toward its climate policy goals more transparent. New York's Climate Action Council had its first meeting yesterday. NYPIRG made that the occasion to propose "Clear and Accessible Public Reporting on Climate Progress" nypirg.org/pubs/202003/Le… 1/5
Feb 26, 2020 10 tweets 4 min read
National Grid, 1 of 2 utilities that provides NYC & Long Island gas service, has issued a rpt on gas supply options for the next 15yrs. Numbers aside, the framing is useful for anyone thinking about electrifying heating loads in downstate New York. perma.cc/WLA8-2MTG

1/10 ImageImage Quick context(1/2): New York won’t permit development new gas transmission pipelines, Nat’l Grid issued a (sudden) moratorium on new hookups, Gov Cuomo threatened to yank their franchise, Nat’l Grid relented.

For more, see

2/10
Feb 18, 2020 21 tweets 10 min read
I wrote a short piece about climate litigation (Nature Energy calls it a "Comment"). nature.com/articles/s4156…

Here's a (monster) thread that hits some key points and elaborates on a few of them too. The energy sector (oil-n-gas & also electric and gas utilities) faces a rising tide of climate litigation. Well, not a tide, because it’ll likely just keep rising.

Different categories of cases are going to matter in different ways.

1/18
Jan 22, 2020 12 tweets 5 min read
New York wants to develop a huge amount of renewable generation but also to avoid paying more than necessary to procure it.

Enter the (bold! contentious!) Index REC. documents.dps.ny.gov/public/Common/…{1F9CA0EB-3968-41DB-BBE0-C251A3FE52DE}

1/11 Image RPSs require retail utilities to buy a specified fraction of the power they resell to consumers from renewable generators. RECs are the medium of exchange. In NY, renewables get a REC per MWh generated. nyserda.ny.gov/All-Programs/P…

2/11
Jan 22, 2020 10 tweets 5 min read
It's budget season here in New York, and we’re starting to see how the state plans to hit its--as my 2yo would say--veryveryveryvery ambitious renewables deployment target of 70% renewable electricity by 2030 (10yrs!).

2 threads incoming: siting here, then Index RECs.

1/9 Image As usual, @m_jfrench has the story that you should start with. politico.com/states/new-yor…
Mentioned therein (and elaborated on here): possible changes to NY’s siting law & Gov Cuomo’s proposal to “flip” the current siting process.

(Look for a related thread on Index RECs.)

2/9 Image
Jan 16, 2020 11 tweets 5 min read
Thread about early steps/stumbles here in New York State toward a transition away from relying on fossil gas for heating, water heating, cooking, and other applications in buildings.

(Inspired by the hearing currently underway re ConEd’s 2019 rate case proposal)

1/11 Image New York passed the Climate Leadership & Community Protection Act in June 2019. The Act entered into effect on 1/1/2020. It says NY will be carbon neutral in 30 years(!). Even before it took effect, NY had rejected fracking and was resisting fossil gas pipeline development.

2/11 ImageImage
Jan 10, 2020 14 tweets 6 min read
Get ready for the People Are Policy portion of New York climate policy implementation, 'cause the (world leading!) Climate Leadership & Climate Protection Act won't implement itself.

So, a thread on the Climate Action Council, the body that will steer CLCPA implementation 1/12 Image First, some dates and deadlines. The legislature passed the CLCPA in June 2019, at the very end of the legislative session. The Governor signed it in July (Al Gore was there and signed something too. Not sure what it was or why he signed anything. But he did.) 2/12 Image
Oct 3, 2019 4 tweets 1 min read
!!! To spell that out a bit: Pennsylvania is ranked #3 for coal production, #2 for nat gas production, and #4 for GHG emissions. eia.gov/state/?sid=PA So agreeing to assign a price to fossil fuels is a big political step--hopefully one that presages more in the same direction!