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  • Public Comments

    Comments on FERC’s Potential Reforms to PJM Capacity Market

    November 6, 2018

    After suggesting that state policies subsidizing clean energy are distorting capacity markets, the Federal Energy Regulatory Commission (FERC) is exploring reforms to the capacity market in PJM – the grid operator serving 13 states and Washington D.C. FERC’s reforms have the potential to undermine state policies that address climate change, such as Renewable Energy Credits and Zero Emissions Credits (we discuss this issue in depth in a recent report). We submitted comments to FERC and reply comments on the proposals.

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  • Public Comments

    Comments on New Jersey’s Energy Master Plan

    October 15, 2018

    New Jersey is revising its Energy Master Plan (EMP) for 2019. In advance of the first draft of the plan, the New Jersey Board of Public Utilities, along with other state agencies, formed a committee to engage with stakeholders on the contours of the new plan. We submitted comments to the EMP Committee with a number of recommendations. Specifically, in drafting the 2019 EMP, we advise the Committee to consider grid resilience in a holistic manner and apply cost-benefit analysis to resilience plans and investments; adopt a granular approach to rate design, rather than use net metering; and design an incentive structure for energy storage operators to ensure that the use of energy storage systems reduces greenhouse gas emissions. These recommendations draw upon several of our recent publications on electricity policy, including reports on grid resilience and energy storage, and an academic article, also on energy storage. The first draft of the EMP is scheduled to be released this winter.

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  • Public Comments

    Comments to the California PUC on Energy Storage

    September 26, 2018

    We recently submitted comments to the California Public Utilities Commission on the Self-Generation Incentive Program (SGIP). Retrospective review of SGIP has found that, contrary to the program’s goals, greenhouse gas emissions sometimes increase when energy storage systems are deployed. To address this unintended consequence, the CPUC Energy Division Staff issued a set of recommendations on how to improve the program, including by creating a real-time greenhouse gas emissions factor for energy storage operators to use, and by tying the SGIP incentive payments to greenhouse gas performance. Our comments provide the CPUC with our original analysis on energy storage to support these recommendations, including our recent report, Managing the Future of Energy Storage, and an academic article, by Policy Integrity’s Director, Richard Revesz, and Energy Policy Director, Burcin Unel, Ph.D, on energy storage and greenhouse gas emissions.

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  • Public Comments

    Comments on Vermont’s Standard Offer Program

    September 21, 2018

    We recently submitted comments on Vermont’s standard offer program, which is designed to support smaller-scale renewable energy projects. One component of the standard offer program compensates generators that provide benefits to grid operation and management. In the past, the Vermont Public Utilities Commission has focused its view of these benefits to reward only generators that relieve transmission constraints. However, our comments urge the PUC to take a broader view of benefits to grid operation and include resilience benefits and avoiding climate effects on the grid. We cite our July 2018 report, Toward Resilience, to give the PUC more guidance on how to think about and value grid resilience. We also recommend that, when more broadly assessing the entire standard offer program’s benefits, the PUC should monetize any avoided climate externalities by using the social cost of greenhouse gases.

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  • Public Comments

    Comments to Virginia on Integrated Resource Planning

    September 21, 2018

    We recently submitted comments to the Virginia State Corporation Commission on the integrated resource plan (IRP) of the Appalachian Power Company. These comments focus on how the Commission should require utilities to analyze climate impacts when planning how to balance future fossil fuel-based electricity generation against renewable energy options. Under the Virginia Code, the Commission is required to consider whether IRPs are “reasonable” and “in the public interest.” We make the case that climate damages fall squarely within the realm of public interest. Therefore, we argue that the Commission should require electric utilities to more transparently quantify the greenhouse gas emissions of alternatives, and to monetize the associated climate damages using the Social Cost of Greenhouse Gas metrics. Such analysis is necessary to allow the Commission to rationally identify the most efficient plan option that advances social welfare for Virginia, and to allow ratepayers and citizens to better understand the environmental effects of the portfolios chosen.

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  • News

    Cost of Carbon Website Relaunched

    September 13, 2018

    Costofcarbon.org is now home to our ongoing work on the social cost of carbon (SCC) in U.S. state policy. The domain, which housed SCC-focused research until 2015, has been renovated and refocused to reflect the most important and relevant developments in the application of the SCC in decisionmaking. It includes an easy-to-navigate version of our FAQ Guide for state policymakers, information on state-specific use of the SCC, helpful resources, and more. Our hope is to bring attention to the ways that the SCC continues to be a critical tool used by policymakers in a number of areas, from electricity rate design, to cap-and-trade programs, to fossil fuel royalty rates. A diverse array of stakeholders can benefit from the site’s information and we invite feedback from regulators, partners, and the public on new proceedings that make use of the SCC or matters in which the SCC might be applicable.

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  • Public Comments

    Comments on New York State Energy Storage Roadmap

    September 10, 2018

    In June 2018, the New York State Department of Public Service and the New York State Energy Research and Development Authority released the New York State Energy Storage Roadmap, outlining a series of recommended approaches to achieve Governor Cuomo’s statewide energy storage target of 1,500 MW by 2025. Our comments, based on our Managing the Future of Energy Storage report, generally support the overall approach to reward energy storage systems for all the values they can bring to the electric system, to allow dual participation in both wholesale and retail electricity markets, and to improve price signals to maximize the benefits of energy storage systems.

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  • Public Comments

    Policy Integrity Input Leads to Climate Progress in Nevada

    August 30, 2018

    Input from the Institute for Policy Integrity helped encourage Nevada to modernize its energy policymaking by accounting for the impacts of carbon pollution in key electric utility planning decisions. At the recommendation of Policy Integrity and partner groups, the Public Utilities Commission of Nevada recently included language on the Obama-era Interagency Work Group’s Social Cost of Carbon (SCC) in new rules governing utilities’ resource plans.Utilities will now have to analyze and clearly disclose the damages caused by climate change when evaluating alternative long-term resource plans. This information will be used by utilities and the Commission when selecting their preferred resource plan.

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  • Academic Articles/Working Papers

    The Future of Distributed Generation

    August 8, 2018

    As distributed energy generation is becoming increasingly common, the debate on how a utility’s customers should be compensated for the excess energy they sell back to the grid is intensifying. And net metering, the practice of compensating for such energy at the retail rate for electricity, is becoming the subject of intense political disagreement. Utilities argue that net metering fails to compensate them for grid construction and distribution costs and that it gives rise to regressive cost shifting among its customers. Conversely, solar energy proponents argue that the compensation should be higher than the retail rate to account for other benefits that distributed generation systems provide, such as the resulting climate change and other environmental benefits, as well as the savings resulting from not needing to build new installations to provide additional capacity. This ongoing debate is leading to significant changes to net metering policies in many states.

    This article provides an overview of the benefits and the costs of distributed generation and highlights the analytical flaws and missing elements in the competing positions and in most existing policies. We propose an alternative approach that recognizes the contributions to the electric grid of both utilities and distributed generators. The article is excerpted and revised from a longer academic article, Managing the Future of the Electricity Grid: Distributed Generation and Net Metering, which was selected by Environmental Law Reporter as one of the five best environmental law articles published in the 2016-2017 academic year.

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  • Reports

    Toward Resilience

    August 1, 2018

    Grid resilience—generally, the electric grid’s ability to resist/absorb, manage, quickly respond, and recover from/adapt to high-impact, low-probability external shocks—has been a concern for electric utilities and energy planners for decades. While recent extreme weather and cyber security concerns have prompted the federal government to pursue policies that support coal and nuclear power plants, a more systematic focus on resilience will lead to very different solutions than what has been proposed by the Department of Energy.

    Our report aims to assist policymakers in understanding grid resilience and evaluating potential interventions aimed at improving grid resilience. It develops a definition of resilience grounded in academic literature; describes a methodology for calculating the costs and benefits of potential grid resilience improvements; identifies legal authorities that states and federal agencies can use to implement resilience-enhancing policies and investments; and analyzes the Trump Administration’s proposals to support coal and nuclear plants in light of the insights developed in the report.

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