The team at 38 North has found that, while it is important to work closely with EPA on their important carbon-related rule-makings and to keep Congress informed on a wide variety of topics and issues, much of the real action in clean energy is taking place in the states. Statehouses and utility commissions are setting policies for renewables, energy efficiency, demand response, energy storage, and other distributed energy resources, that can change the energy mix in our country. This will certainly bode well as states develop their compliance plans for the EPA Clean Power Plan to reduce greenhouse gas emissions under Section 111(d) of the Clean Air Act.
An example of a major state policy initiative is the New York “Reforming the Energy Vision” that will significantly change the way utilities interact with consumers. Under a grant from the Energy Foundation, we teamed up with Jon Wellinghoff, former Chairman of the Federal Energy Regulatory Commission, to submit comments recommending that the New York Public Service Commission adopt an Independent Distribution System Operator structure that would move utility operations to an operator similar to the wholesale Independent System Operator and open up competition on the distributed side of the grid for a variety of participants. As with this filing, we continue to provide policy analysis and strategic direction to stakeholders and clients in states where clean energy policies are on the docket.