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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
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
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
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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The Role of Electricity Tariff Design in Distributed Energy Resource Deployment
This paper simulates the effect of more advanced residential electricity tariffs on household adoption of distributed energy resources (DERs). We find that tariffs that are more time variant lead to greater reductions in coincident peak demands than flat volumetric tariffs, both from load shifting as well as from adoption of DERs. Regarding the effect of electricity tariff design on DER investments, we find that at current DER purchase costs investments in rooftop photovoltaic (PV), batteries and natural gas distributed generators are not privately optimal under any of our tariff design scenarios based on current cost levels for electricity and gas in the Chicago study area.
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Rate Design and Distributed Energy Resource Integration: Impacts on the Environment and Distribution System Costs
This project looks at the effects of different retail tariff designs on the deployment of distributed energy resource (DERs), and their subsequent effect on pollution, electric system costs, and customer bills. We use smart-meter data and techno-economic models to simulate the effects of more granular and cost-reflective tariff designs on DER investment and use.
This project is supported by the Alfred P. Sloan Foundation, and is a collaboration between the Institute for Policy Integrity, Environmental Defense Fund, and the MIT Energy Initiative.
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Building a New Grid Without New Legislation
A Path to Revitalizing Federal Transmission Authorities
In the absence of legislation, critical long-distance transmission can be developed by applying existing federal legal authorities. A number of important regulatory and commercial measures have been proposed, including streamlining transmission planning, upgrading existing transmission system components, putting transmission lines underground, and using existing rights-of-way from highways and railroads. Even if these solutions are adopted, however, state siting requirements may prove an important obstacle to developing an efficient, national transmission grid. So, this paper examines legal authorities already available to the Department of Energy and the Federal Energy Regulatory Commission to develop the interstate transmission capacity crucial to the energy transition.
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