Justin Gundlach

Adaptation as Risk Management Agency Filing Risk Management

Comments on Federal Agency Climate Adaptation and Resilience Plans

These comments support the development of the Federal Agency Climate Adaptation and Resilience Plans, which establish a foundation for actions to protect government operations and facilities, and all who rely upon them. The comments recommend that agencies consider the following steps as they build on that foundation: (1) Agencies should…

Justin GundlachNovember 5, 2021

Adaptation as Risk Management Agency Filing Energy Regulation Federal Energy Regulation Risk Management

Supplemental Comments on FERC’s Technical Conference on Climate Change, Extreme Weather, and Electric System Reliability

These post-technical conference comments provide further recommendations on how FERC can support effective climate resilience planning throughout the energy system, supplementing an earlier set of pre-technical conference comments.

Justin GundlachSeptember 27, 2021

Adaptation as Risk Management Agency Filing Energy Regulation Risk Management State Energy Regulation

Comments to Michigan PSC on Electric Utility Planning Processes to Prepare for Climate Change

These comments to the Michigan PSC recommend that it require electric utilities under its jurisdiction to regularly assess their climate-related vulnerabilities and identify measures to make their systems resilient to climate impacts.

Justin GundlachSeptember 24, 2021

Blog/News Article Financial Disclosure Financial Regulation

Utilities Should Be Required to Disclose Their Climate-Related Financial Risks

This article describes why states should ensure utilities are disclosing climate risk to their assets and operations.

Justin GundlachDecember 15, 2020

Agency Filing Financial Disclosure Financial Regulation

Comments on New York PSC Proceeding on Climate Risk Disclosure

These comments argue that New York State should require its electric and gas utilities—not their holding companies but the operating utilities themselves—to assess and disclose the climate risks they face.

Justin GundlachDecember 9, 2020

Adaptation as Risk Management Journal Article Risk Management

Climate Risks Are Becoming Legal Liabilities for the Energy Sector

The number of plaintiffs taking energy firms to court for ignoring climate-related risks is growing. By revealing how the sector is not prepared—and not preparing—for what is coming, their cases are pressing the energy sector to treat those risks as a cost of doing business.

Justin GundlachFebruary 17, 2020

Adaptation as Risk Management Agency Filing Energy Regulation Risk Management State Energy Regulation

Comments to Connecticut PURA on Value of Distributed Energy Resources

These comments to the Connecticut Department of Energy and Environmental Protection and Public Utilities Regulatory Authority discuss their proposed distributed energy resource value categories, encouraging the agencies to include electricity system resilience and community resilience in their list of value categories.

Justin GundlachAugust 21, 2019

Adaptation as Risk Management Energy Regulation Federal Energy Regulation Report Risk Management

Climate Change Impacts on the Bulk Power System: Assessing Vulnerabilities and Planning for Resilience

This report discusses recommendations for grid operator climate change planning.

Justin GundlachFebruary 20, 2018

Adaptation as Risk Management Energy Regulation Federal Energy Regulation Journal Article Risk Management State Energy Regulation

Microgrids and Resilience to Climate-Driven Impacts on Public Health

This article examines how the definitions of resilience adopted by the public health and electricity communities can, but do not necessarily, converge in responses to electricity outages so severe that they affect the operation of critical infrastructure, such as wastewater treatment and drinking water facilities, hospitals, and cooling centers. The…

Justin GundlachFebruary 1, 2018

Agency Filing Risk Management

Comments on Draft Nationwide Programmatic EIS for the National Flood Insurance Program

These comments discuss the 2017 draft Nationwide Programmatic Environmental Impact Statement for the National Flood Insurance Program.

Justin GundlachJune 1, 2017