Climate Lobbying Overview: NRG Energy appears to have a mixed position on climate change. While it is actively engaged in a number of climate and energy policy discussions in the US, the company often appears to push particular policy forms that it considers best for developing clean energy market, most notably the Forward Clean Energy Market. In multiple instances, the company’s support for such policy has been accompanied by pushback on other forms for climate policy already in place, or being proposed by regulators.

Top-line Messaging on Climate Policy: As of 2019, NRG Energy has stated its support for the Paris Agreement and complementary initiatives to achieve its goals. NRG appears to advocate for the need for market-based measures to address climate change over other forms of regulation. This is evident, for example, in February 2020 comments on Connecticut’s Integrated Resource Plan. Despite this, the company has frequently stated top-line support for an economy-wide price on carbon and clean energy standards.

Engagement with Climate-Related Regulations: NRG Energy appears to have mixed positions on climate-related regulations. The company stated support for net metering policies in its 2020 CDP response and, as evident on its website, appears to support policy-measures that aid the development of community solar initiatives. Meanwhile, November 2019 comments to the New York Public Service Commission appear to argue against renewable portfolio standards.

While NRG has frequently advocated to policymakers for a national price on carbon, for example in a September 2020 testimony to FERC, May 2020 comments to the New Jersey Board of Public Utilities appear to oppose carbon taxes, arguing that paying clean energy resources is favorable to taxing emitting entities. Despite this, the company’s 2019 Sustainability Report advocated for the adoption of a national carbon price to replace other existing forms of climate regulation. In 2018, NRG supported Connecticut’s statewide emissions target, although October 2020 comments to the California’s Public Utilities Commission do not take a clear stance on the state’s GHG emissions reduction target.

Positioning on Energy Transition: NRG is actively engaged with policy discussions on the transition of the energy mix, with positions that often appear to prioritize economic competitiveness and cost-effectiveness over the need to rapidly decarbonize the energy mix. Evident in an October 2018 brief to FERC, NRG has supported capacity market mechanisms that would extend the life of GHG emissions intensive power sources. More recently, the company has advocated for a Forward Clean Energy Market (FCEM), a concept that would create a competitive market for clean energy credits. This can be seen in comments to public utilities commissions in New York (November 2019) and New Jersey (May 2020), both of which offer FCEM as a solution to prioritize competition-preserving, market-based mechanisms over other forms of policy. Throughout 2019 and 2020, NRG [731129 actively opposed Illinois’ Clean Energy Jobs Act, which mandated a statewide clean energy goal, instead introducing its own “technology-neutral” clean energy legislation. The company submitted comments in support of a 2020 Maryland bill that would require the decarbonization of the state’s power sector and implement a FCEM for competitive energy growth. NRG generally supported the federal CLEAN Future Act (sets a 100% clean energy by 2050 goal) in June 2020, but advised amendments that prioritize market-based measures over other policy mechanisms to reach the bill’s goals.

NRG has advocated for strong policies to support the growth of EV infrastructure, evident in August 2020 comments to the Public Utilities Commission of Texas. July 2020 comments to Pennsylvania’s Public Utilities Commission also suggest NRG actively supports the growth of renewables in the energy mix. A 2018 CEO statement and NRG’s 2019 Sustainability Report both propound the long-term importance of natural gas in the energy mix without specifying clear conditions related to carbon capture and storage technologies (CCS). NRG reportedly advocated in support of the USE IT Act in 2019, a CCS research and development bill.

Industry Association Governance: NRG’s corporate website provides limited transparency on its memberships to industry associations and particularly on its alignment with the organizations’ climate policy positions. NRG Energy is a member of the Solar Energy Industries Association and the American Wind Energy Association, both of which have actively lobbied for ambitious climate policy in the US. NRG is also a member of the National Petroleum Council and the Business Roundtable (BRT), both of which have engaged in obstructive lobbying on climate and energy policy in the US, albeit with some recent improvements from BRT.