Skip to content


Articles and Book Chapters


  • Comments to U.S. EPA regarding Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles (July 2023).
  • Comments to U.S. EPA regarding implementation of the Carbon Pollution Reduction Grant program established by the Inflation Reduction Act (Jan. 2023)(relating to optimizing implementation of the program for states with existing climate programs).
  • Comments to FERC on a petition submitted by the New England Ratepayers Association. (June 13, 2020)(relating to legislative history of the netmetering provision enacted in the Energy Policy Act of 2005).
  • Comments on the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule (Oct. 26, 2018)(relating to the U.S. EPA and DOT’s argument that state emissions standards for greenhouse gases are preempted by the Energy Policy and Conservation Act of 1975).

For all of Greg’s work, please check out his SSRN page.