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  • Electricity Tariff Design via Lens of Energy Justice Cover

    Electricity Tariff Design via Lens of Energy Justice

    Distributed Energy Resources (DERs) can significantly affect the net social benefit in power systems, raising concerns pertaining to distributional justice and equity. Current tariff design approaches suffer from opaque efficiency-equity trade-offs and are also agnostic of the externalities that affect both economic efficiency and equity. Therefore, this paper develops a justice-cognizant tariff design framework that improves the operational savings in the system without sacrificing distributional equity, and encompasses economic welfare, social costs of environmental and public health impacts, and socio-economic and demographic characteristics of electricity consumers. We evaluate four different tariff structures using a Multi-Objective Problem with Equilibrium Constraints. We then compare the operational savings and equity of the proposed framework using the 11-zone New York ISO and 7-bus Manhattan power networks. The results demonstrate that justice-cognizant, and spatially- and temporally-granular tariffs ensure equity and increase the operational savings at a lower energy burden to consumers.

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  • Comments to PUCT on Wholesale Electricity Market Design

    The Texas Public Utility Commission (PUCT) requested public input as part of an ongoing effort to ensure the reliability of its wholesale electricity market design following Winter Storm Uri. We submitted comments on how the PUCT can achieve its reliability goals in a manner that ensures just and reasonable rates for consumers. For any new mechanism it may deem necessary, we encouraged the PUCT to choose a design that accords with economic principles. Such a design would compensate both dispatchable and non-dispatchable resources according to their reliability value, include an efficient penalty structure for non-performance of generation units, reduce uncertainty for market participants, and mitigate market power exercise.

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  • Policy Brief and Supplemental Comments on the FERC Transmission Planning Rule and the Major Questions Doctrine

    Together with Harvard’s Electricity Law Initiative, we prepared a policy brief and supplemental comments defending the Federal Energy Regulatory Commission’s (FERC) proposed rule on transmission planning reform from arguments that the proposal would trigger the major questions doctrine. We review previous transmission planning regulations and orders by FERC to explain that the major questions doctrine does not apply because the proposed rule is neither unheralded nor transformative.

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  • Enacting the  “Polluter Pays” Principle Cover

    Enacting the “Polluter Pays” Principle

    New York’s Climate Change Superfund Act and Its Impact on Gasoline Prices

    This policy brief analyzes how New York State’s recently proposed Climate Change Superfund Act is most likely to affect consumer gasoline prices. The Act would require payments from fossil-fuel companies based on their historical contributions to current greenhouse gas levels in the atmosphere. The payments would be used to build green infrastructure to help the state adapt to climate change. The brief finds that the Act would likely have a negligible impact on current and near-term oil prices, while potentially lowering future energy prices in New York, including for transportation.

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  • Who Knows What: Information Barriers to Efficient DER Roll-Out Cover

    Who Knows What: Information Barriers to Efficient DER Roll-Out

    Published in International Association of Energy, Environment and Economy Journal

    While academic research on Distributed Energy Resources (DERs) has been mostly focused on first-best systems, we hypothesize that in reality multiple information barriers to efficient DER roll-out exist. We thus study the prevalence and importance of information issues arising in the context of deployment of DERs by reviewing the existing engineering and economic literature on distributed resources, analyzing DER-related regulatory proceedings, and surveying the relevant electricity sector stakeholders for their perception of information relevance and accessibility.

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  • Comments on Resource Adequacy to NJ Board of Public Utilities

    The New Jersey Board of Public Utilities (BPU) requested public input on its 2022 Progress Report on New Jersey's Resource Adequacy Alternatives, part of its continuing investigation into achieving New Jersey's resource adequacy and clean energy objectives. We submitted comments identifying specific recommendations for the BPU regarding the implementation of the proposals sets forth in the Progress Report. Among other recommendations, we encouraged the BPU to continue exploring the possibility of indexing renewable energy credits and clean energy attributes to the emissions intensity of displaced generation, identified various challenges associated with its proposal to introduce a market for clean capacity credits, and encouraged the BPU to carefully consider the preemption risk associated with its clean capacity credits market proposal.

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  • The Role of Information in Distributed Energy Resource Deployment and Policy Cover

    The Role of Information in Distributed Energy Resource Deployment and Policy

    While appropriate compensation for DERs has received considerable attention in DER policy discussions, one important dimension has received less attention: informational gaps and asymmetries. In particular, key information about distribution networks, energy consumption, and marginal emission rates is often either entirely lacking or readily available only to some parties. Such information disparities can impede effective policymaking. To overcome the inefficiencies information asymmetry creates, regulators must carefully tailor disclosure mandates and incentives for utilities, as these actors often have little incentive to go beyond the letter of the law in data disclosure.

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  • Impact of Imperfect Foresight on Optimal DER Deployment, Remuneration and Policy Cover

    Impact of Imperfect Foresight on Optimal DER Deployment, Remuneration and Policy

    Published in Applied Energy

    This paper proposes a decision-making framework to optimize electricity tariffs and remuneration policy for renewable energy sources operating in transmission- and distribution-level (T&D) marketplaces. The authors develop perfect and imperfect foresight models with a multi-level structure to investigate the effects of the inability of actors to correctly predict future remuneration on the efficiency of the decisions made by policymakers.

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  • Comments to Connecticut on Energy Storage and Emissions

    The Connecticut Public Utilities Regulatory Authority (PURA) issued a straw program design for electric storage. We submitted comments that support PURA's efforts to make energy storage part of its overarching decarbonization agenda and provide feedback. It is important, as we explain, that PURA take into account the potential emissions consequences of energy storage operations in designing its performance-based incentive.

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  • Comments to FERC on Transmission NOPR

    We submitted comments to FERC providing recommendations for how it can clarify and improve reforms proposed in its Notice of Proposed Rulemaking addressing transmission planning and cost allocation. If finalized, the rulemaking would require planning entities to undertake long-term transmission planning. Our comments recommend that FERC clarify (at a high level) what it means to undertake long-term planning over a 20-year time horizon. We also recommend more specific improvements that can be made, including providing minimum uniform requirements on model specifications and scenario planning based on best practices; instituting administrative guardrails to protect transmission customers from excessive costs if the Commission moves forward with its proposed Right of First Refusal; and mandating a uniform set of core benefits that all planners must consider.

    We also submitted reply comments in the proceeding to underscore two points. In response to commenters that argued the Commission should reconsider its proposal in light of the level of uncertainty surrounding the future, we argue that it is future uncertainty that necessitates the long-term scenario planning contemplated by the rule. Such proactive transmission planning will allow planners to prepare for and react to changing circumstances and ensure a reliable and resilient grid in the face of uncertainty. Additionally, our reply comments reaffirm previous recommendations that the Commission should require planners to use a standardized cost-benefit analysis that properly accounts for societal benefits of new transmission.

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