Explore PECC's advocacy work by reading about the comments submitted to regulatory agencies and decision makers. This page includes summaries of the comments PECC and its members have authored or endorsed, providing clear insight into the key issues, arguments, and recommendations presented.

The New York State Energy Plan is the central policy roadmap for achieving New York’s statutory climate goals, including a 100% zero-emission electricity system by 2040 and an 85% reduction in greenhouse gas emissions by 2050. In its recent public comment submission, available below, the Pace Energy and Climate Center commended the Draft Plan’s reaffirmation of reliability, equity, and affordability as guiding principles, while urging the New York State Energy Planning Board to adopt a more decisive, enforceable framework to meet the mandates of the Climate Leadership and Community Protection Act.

PECC’s recommendations emphasize five key priorities: (1) Phasing out fossil fuels by 2030, with limited reliability exceptions; (2) Accelerating clean energy deployment through coordinated planning and a stepped electrification strategy; (3) Establishing strict lifecycle-based standards for alternative fuels and supporting a Clean Transportation Standard focused on electrification; (4) Scaling up community-led thermal energy networks ("TENs") and recognizing thermal energy’s value in reducing grid costs and building emissions; and (5) Centering affordability by adopting a 6% energy burden benchmark, implementing durable funding mechanisms such as cap-and-invest, and ensuring disadvantaged communities benefit first.

Through these proposals, PECC aims to help transform the Final State Energy Plan into a bold, actionable blueprint for a decarbonized, equitable, and affordable energy future in New York.

On September 22, 2025, a group of 58 Haub Law students submitted a comment urging EPA to abandon its proposed rule, “Reconsideration of the 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.” PECC joined as a signatory, demonstrating its strong support for the comment and the many students who worked on it. The comment advanced three primary arguments which were thoroughly flushed out over 21 pages.

First, despite EPA’s contention that it lacks statutory authority under Section 202(a) of the Clean Air Act to regulate greenhouse gas emissions, such authority has been well established since 2007. In Massachusetts v. EPA, the Supreme Court not only held that GHGs met the Act’s definition of “air pollutant” but also that the EPA has a non-discretionary duty to regulate such pollutants if they endanger public health and welfare.

Second, while EPA asserts unfounded claims that the 2009 Endangerment Finding was based on an unreasonable analysis of scientific data and that new developments cast doubt on such conclusions, the comment explains that the Agency’s reliance on the Department of Energy’s recent “Climate Working Group” report constitutes arbitrary and capricious decision-making in violation of Section 706(2)(a) of the Administrative Procedure Act.

Lastly, the comment addresses EPA’s claims that there is no available technology capable of addressing the identified climate concerns without exacerbating risks to public health and welfare, countering that the Agency is bluntly disregarding decades of regulatory experience, scientific data, proven emission control technologies, and existing enforcement infrastructures.

On September 23, 2025, PECC Executive Board member Kenneth Sumter J.D. '26 submitted a comment, with PECC's signature and full support, in response to New Jersey Department of Environmental Protection's ("NJDEP") review of the proposed Northeast Supply Enhancement ("NESE") project. The project calls for a 37.1-mile expansion of the existing Transco natural gas pipeline, stretching from Pennsylvania through New Jersey and into New York. The gas resulting from this expansion will serve New York customers, yet New Jersey is left shouldering the environmental consequences.

The comment urges NJDEP to deny the project and details the serious environmental, social, and economic risks it poses on New Jersey communities. In short, this is a short-term fossil fuel expansion benefiting New York with long-term consequences for New Jersey to face. Not only will this project compromise New Jersey's climate goals, but it will damage sensitive ecosystems, and undermine the well-being of New Jersey residents.

On June 2, 2025, the Pace Energy and Climate Center (PECC) filed a submission with the Secretariat of the United Nations Framework Convention on Climate Change (UNFCCC) in response to a call for inputs on the potential impacts of greenhouse gas reduction measures.  The PECC’s submission flows from a program under the UNFCCC and the Paris Agreement that examines the impacts of greenhouse gas mitigation measures, recognizing that sometimes such measures produce negative effects.

To better understand the impacts of greenhouse gas reduction actions, the parties to the UNFCCC and Paris Agreement (the Parties) created in 2018 the Katowice Committee of Experts on the Impacts of the Implementation of Response Measures (KCI), to assist them in sharing information, experience, and best practices on the impacts.  At COP28 in 2023, the Parties tasked the Secretariat (Decision 13/CP.28) to organize two-day global dialogues in 2024 and 2025 on the impact of greenhouse gas reduction measures, in conjunction with the KCI.

Non-party stakeholders, like the PECC, were invited to submit their views on possible topics for the global dialogues. The PECC’s submission, which was prepared by Joseph Siegel, PECC’s outgoing Interim Executive Director, with the assistance of Brooke Wood, PECC Legal Research Assistant, recommends that the Secretariat include, as a topic in the 2025 global dialogue, the potential for conflict to emerge from greenhouse gas reduction actions.

The submission provides examples of conflict and tensions stemming from greenhouse gas reduction actions, such as community opposition to solar installations, lawsuits against wind projects, and conflicts from mining minerals that are needed for decarbonization technologies.  The PECC’s submission also discusses the opportunities for broader use of conflict resolution, conflict prevention, and conflict management strategies, which can be effective in addressing greenhouse gas mitigation-related conflicts and tensions. It then suggests the benefit of using mediators and third-party impartial facilitators to design and implement processes for conflict resolution, prevention, and management.  Finally, the PECC makes recommendations to the Secretariat and KCI on designing the two-day dialogue to maximize its effectiveness.

PECC’s submission can be found here.

• 10/26: Comments due on Utility Stage 2 Design Studies for UTEN Pilots in Case 22-M-0429, focused on pilot design plans under the Utility Thermal Energy Network and Jobs Act ("UTENJA") of 2022.
• 11/9: Comments due on Upstate and Downstate Regional Residential Weatherization Proposals in Case 25-M-0248, addressing 2026–2030 non-LMI energy efficiency and building electrification portfolios.