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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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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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Mandating Disclosure of Climate-Related Financial Risk
Climate change presents grave risk across the U.S. economy, including to corporations, their investors, the markets in which they operate, and the American public at large. Unlike other financial risks, however, climate risk is not routinely disclosed to the public. This report, authored by Policy Integrity and the Environmental Defense Fund, urges the Securities and Exchange Commission to issue new, mandatory disclosure rules focused on climate risk.
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Corporate Climate Risk: Assessment, Disclosure, and Action
Conference Brief
On October 2, 2020, the Institute for Policy Integrity and the Volatility and Risk Institute at NYU Stern School of Business convened a conference bringing together investors, companies, researchers, and regulators to discuss climate-related financial risks and identify opportunities to better assess, report, and act on them. This brief summarizes some of the major points of discussion from the conference, which featured different perspectives on various policy, economic, and legal issues.
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Improving Environmental Justice Analysis
Executive Order 12,898 and Climate Change
Distributional and equity concerns have typically received short shrift in federal administrative decisionmaking, particularly with regard to actions with climate-change impacts. This report aims to aid advocates and policymakers in meaningfully addressing the disparate climate impacts of federal actions.
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Bostock and the End of the Climate Change Double Standard
Guided by the blueprint of all three Bostock opinions, this article, published in the Columbia Journal of Environmental Law, performs a deep dive into the legislative materials surrounding the enactment of the Clean Air Act of 1970, uncovering a treasure trove of sources that had not previously been part of the public discourse. It shows how, under the interpretive approach of each of the three opinions, greenhouse gases are unquestionably pollutants for the purposes of the Clean Air Act. Because the approaches in the majority and dissents in Bostock—and thus a majority of the current Court—all point in the same direction, the era of greenhouse gas exceptionalism should now be over.
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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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Turbocharged
How One Revision in the SAFE Rule Economic Analysis Obscures Billions of Dollars in Social Harms
This report is part of a series that documents how the assumptions underlying The Safer Affordable Fuel Efficient (SAFE) Vehicles Final Rule for Model Years 2021–2026 Passenger Cars and Light Trucks are skewed to make the rule look less harmful than it actually is. In this report, we focus on the rule’s estimate of vehicle sale price elasticity, which substantially inflates the rollback’s effect on new vehicle purchases.
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