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  • Comments to DOE on Process Rule for New Energy Conservation Standards

    The Department of Energy proposed revisions to its procedures and policies for considering new energy conservation standards across a range of consumer products and commercial equipment. We submitted comments offering support for the proposed revisions and making additional recommendations. Our recommendations include weighing a full range of environmental and consumer effects, incorporating the consideration of distributional justice, and reviewing the selection of discount rates. 

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  • Comments to Maryland PSC on Energy Storage Report

    The Maryland Public Service Commission requested input on its working group's energy storage report. We submitted comments in support of several of the working group's recommendations. We also encourage the Commission to apply the same principles that inform the report to assess the net emissions impacts of energy storage installations.

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  • Strategic Policymaking for Implementing Renewable Portfolio Standards: A Tri-level Optimization Approach Cover

    Strategic Policymaking for Implementing Renewable Portfolio Standards: A Tri-level Optimization Approach

    Forthcoming

    Appropriately designed renewable support policies can play a leading role in promoting renewable expansions and contribute to low emission goals. Meanwhile, ill-designed policies may distort electricity markets, put power utilities and generation companies on an unlevel playing field and, in turn, cause inefficiencies. This paper, forthcoming in IEEE Transactions on Power Systems, proposes a framework to optimize policymaking for renewable energy sources, while incorporating conflicting interests and objectives of different stakeholders.

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  • Comments to New York PSC on Gas Planning Procedures

    The New York Public Service Commission requested input on its Staff Gas System Planning Process Proposal. We submitted comments encouraging the Commission to add several minor requirements and directly address the legal tensions and ambigious policies that make planning decisions more challenging.

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  • Comments to FERC Following Technical Conference on Market Design

    The Federal Energy Regulatory Commission (FERC) requested input on the expanded minimum offer price rule (Expanded MOPR) in the PJM capacity market, as well as prospective alternative approaches that could replace PJM's Expanded MOPR. We submitted comments addressing the questions posed while drawing attention to reforms that FERC should undertake.

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  • Resource Adequacy in a Decarbonized Future Cover

    Resource Adequacy in a Decarbonized Future

    Wholesale Market Design Options and Considerations

    This report examines the relationship between resource adequacy and renewable energy. It explores the impacts of renewables on the functioning of resource adequacy mechanisms and how different resource adequacy approaches affect renewable investment, finding that current approaches—with certain adjustments—are capable of ensuring that the lights stay on during a future that is powered largely by renewable energy.

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  • Comments on New York PSC’s Initial Report on Power Grid Study

    The New York Public Service Commission (PSC) requested input on its initial report on the New York Power Grid Study. Our comments recommend steps the PSC can take to not only achieve emissions reduction goals, but also give appropriate priority to environmental justice.

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  • (Not So) Clean Peak Energy Standards Cover

    (Not So) Clean Peak Energy Standards

    Growth in electricity storage has the potential to increase emissions from power generation. Concerns about this outcome are currently prompting many policies to address the issue. We study a particularly popular policy proposal called the “Clean Peak Standard” that incentivizes storage to discharge during periods of high electricity demand. The stated goal of the policy is to shift storage discharge to offset production from generators with high pollution emissions. We show that the policy is largely ineffective at achieving this emissions reduction goal. The policy reinforces existing incentives faced by storage operators, so it does not have a strong effect on discharging behavior. It is also unable to capture high-frequency changes in marginal operating emissions rates. Alternative policies, such as a carbon tax, are more effective at reducing the emissions increase caused by storage. Policymakers considering Clean Peak-style policies should instead consider these alternative policies.

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  • Comments to DOE on Future Energy Conservation Rulemakings

    The Department of Energy called for input on its prioritization process for energy conservation rulemakings. We submitted comments detailing immediate, mid-term, and long-term actions that DOE can take to more efficiently set energy conservation standards and deliver greater benefits to consumers, public health, and the environment.

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  • Retail Electricity Tariff Design, Distributed Energy Resources, and Emissions Cover

    Retail Electricity Tariff Design, Distributed Energy Resources, and Emissions

    In this paper, we use an economics-engineering simulation model to analyze how different types of residential retail tariff designs such as time-of-use, critical-peak pricing, and fully cost-reflective tariffs affect DER deployment and use, and, hence, the resulting emissions of CO2, SO2, and NOx in the Commonwealth Edison service territory in Chicago. Our results show that in the short term retail tariffs can help or hinder environmental goals through their effect on DER deployment and consumption behavior, emphasizing the importance of pairing DER policy initiatives with decarbonization efforts at the wholesale electricity level.

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