Reports

  • Comment on the Heat Island Criteria filed in NYS PSC Case 24-M-0586

    Submitted to the New York State Public Service Commission. Utility companies in New York were granted the authority to define heat island boundaries throughout the state, which would identify which communities were eligible for extra protected days from utility shutoffs during heat waves. We re-implemented the proposed heat island criteria and found that making small plausible changes to the criteria could shift coverage for hundreds of thousands of residents. We make some technical recommendations, as well as promote procedural justice and community co- development of heat island criteria.

  • Comment on CalEPA's 2026 Disadvantaged Communities designation

    Submitted to the California Environmental Protection Agency regarding its 2026 Disadvantaged Communities designation, which determines where SB 535 funding goes. Our research found that the algorithm used to guide funding is too volatile to be the sole basis for decision-making. We recommend evidence-based solutions to algorithmically guide funding, prioritizing the specific needs of frontline communities.

  • Comment on EPA's proposed Lead and Copper Rule Improvements

    Submitted to the US Environmental Protection Agency on its proposed Lead and Copper Rule Improvements. The comment argues that the interim water filter program is too narrow and that the economic analysis leaves out preterm births and much else that cannot be priced.