Vermont Decarbonization Updates
The Energy Clinic’s Net Zero Affordable Housing Team continues to advocate for stronger energy efficiency standards in manufactured housing. Partnering with national organizations, like Earth Justice and the American Council for an Energy Efficient Economy, the team recently submitted comments urging the Department of Energy (DOE) to expedite the implementation of robust energy efficiency standards and effective enforcement mechanisms for all new manufactured homes. Manufactured homes typically cost less to build than traditional housing, but they are notoriously drafty and energy inefficient. Their energy inefficiency increases energy use, produces excess GHG emissions and burdens their residents, who are typically low-income, with high energy bills. According to the DOE, occupants of manufactured homes spend a staggering 70% more on energy costs per square foot compared to other housing types. With nearly 100,000 new manufactured homes constructed annually, the urgency to implement stringent energy efficiency standards cannot be overstated.
 
Our comments urged the adoption and enforcement of new efficiency standards governing the thermal envelope (insulation, vapor barriers, floors, windows, etc.), appliances, and lighting because the opportunity to mitigate energy demand and reduce greenhouse gas emissions. We demonstrated that the standards will also enhance the health, safety, and comfort of manufactured home residents.
 
Team Leader: Jenny Carter JD’86/MSL’87
Team Members: Abigail Adaway MCEP’24, Kelsey Dannenbaum MERL’24, Drew McCormick JD’24, Alema Sahbaz JD’24, Jason Ward JD/MELP’24
 
Caribbean Renewable Energy Updates
The IEE, in collaboration with the U.S.-Asia Partnerships for Environmental Law, is preparing a comparative analysis of the renewable energy transition in the Caribbean that will be shared with leading Chinese scholars and policymakers. Our research has found that the Caribbean’s transition is primarily driven by energy security concerns, as heavy dependence on oil imports and the accompanying price volatility seriously weakens key economic sectors and hampers sustainable development.
 
Across the Caribbean, the common hurdle blocking the renewable energy transformation is project financing. Solving this problem requires a multifaceted approach. Caribbean governments must continue improving their regulatory frameworks, partner with multilateral development banks to craft bankable projects, and utilize CARICOM institutional powers to create multi-national regional projects.
 
In April, we had the pleasure of hosting David Goldwyn, chairman of the Atlantic Council Global Energy Center’s Energy Advisory Group, for a guest lecture. Eduardo attended the 16th Caribbean Renewable Energy Forum in Miami from April 24–26 to network with regional experts and government officials. A policy brief will be published this summer.
 
Team Leaders: Eduardo Otero Bakai LLM’25 and Will Fridlund
Team Members: Michelle McMillan JD’25, Theo Rose JD’24, Rachel Shoemaker JD’25
 
Offshore Wind – Community Benefit Agreements
The institute, with support from The Nature Conservancy, is continuing its work on accelerating the equitable development of U.S. offshore wind generation. The IEE’s current research project is on the use of community benefit agreements in offshore wind projects in the United States as a means of distributing the benefits of development. There will be significant impacts on local communities as the U.S. moves towards its federal goal of 30 GW of offshore wind by 2030 and states seek to procure more than 70 GW of capacity. Local communities hosting critical infrastructure—port expansions, transmission lines, and substations—should directly benefit from the projects. Community benefit agreements are the mechanism that can provide procedural and distributive equity to affected communities.
 
The IEE team is researching whether current federal and state solicitation processes encourage the use of CBAs or could be amended to allow for CBAs. Our research has also revealed the critical role of the processes to approve infrastructure siting as an opportunity to include community benefit agreements. The final part of our project is to catalogue the different options for distributing benefits including community benefit agreements, host community agreements, payment in lieu of taxes, and other community-directed benefits. Lastly, we are developing a set of best practices based on our North American research that is supplemented by analysis of European and Australian practices. Our recommendations cover how to support participants in the development of agreements, create transparency for negotiated agreements, establish baselines for minimum compensation amounts, and create governance structures that allow communities to direct the disbursement of funds.
 
Team Leader: Mark James
Team Members: Ashlynn Bean JD/MERL’24, Michelle Medina-Bennet JD’25, Dawson Vandervort JD/MERL’24, Ervin Yahr III JD/MERL’24
 
Battery Storage in the United Kingdom, European Union, and United States
A team of IEE researchers will be presenting a comparative analysis of battery storage interconnection and market participation rules in the United Kingdom, European Union, and United States at the 8th Annual Energy Transition Conference to be held at the University of Eastern Finland on June 27-28.
 
Battery storage is a key component of the transition to a net-zero energy system as they break the temporal connection between energy generation and consumption. Batteries enable higher levels of intermittent renewable energy generation to be connected to the grid through better management of peak demand and peak production. As battery technology improves, so does the potential for batteries to accelerate the clean energy transition. However, the speed and scale of the battery build out depends on the rules for how quickly batteries can be connected to the grid and what markets batteries can bid their services into. Those rules, set by governments and market operators, will significantly impact our ability to decarbonize the grid.
 
This paper examines the critical role of interconnection and market participation rules in three different jurisdictions to identify and elevate best practices.
 
Team Leader: Mark James
Team Members: Ace Dantzler-Woodruff JD’25, Taylor O’Hare JD’26/MELP’24, Samantha Privett JD’25

New Hampshire Low Income Solar Update
The VLGS Energy Clinic's New Hampshire Low-Income Solar team has been busy! One project is moving toward completion and the group is preparing to start a new project.

The Pine Hill Cooperative Solar Project is expected to be completed by June 30, 2024. The team started working on this project in 2022 by identifying the host community, applying for and securing grant funding from the New Hampshire Public Utility Commission, drafting and executing a Group Net Metering Agreement, and finalizing an engineering, procurement, and construction contract. After several supply chain delays, the contractor was able to begin construction activities in late 2023.

Most recently, the team has been working on the Pine Gate Cooperative Solar Project, working to bring community solar to the low-moderate income (LMI) residents of Pine Gate Resident Owned Community (ROC). In April 2024, they received notification from the NHPUC that they were successful in winning a $400,000 grant award to support the project. The team has been busy while waiting for the commission's decision. Students helped draft a Benefits Agreement, worked on a parcel merger on the Pine Gate property, and prepared outreach materials for the community and the Cooperative. Next step is to complete an Engineering, Procurement, and Construction (EPC) contract with an expected completion date of October 2024.

Team Leader: Carlson Swafford LLM'25
Team Members: Laura Arboleda Bowie JD'25, Adam Fane JD/MERL'24, Mike Murphy JD/MERL'25, Juan Treviño JD'24, Hayley Wilburn JD'24