A Distributed Energy Amenable Grid

A Distributed Energy Amenable Grid

Pace completed a brief on Puerto Rico’s opportunity to rebuild its grid in a manner that makes the island more resilient. We find that PREPA can take action now to lay a strong foundation for distributed energy resources (DER) to integrate with the transmission & distribution system, by making the right kind of capital equipment investments as it is being rebuilt. The future grid should be designed to accommodate far greater penetration of DER and ought to have the functionality to utilize DER as dynamic assets, supporting the grid. If PREPA fails to take actions to accommodate DER and beneficially utilize their grid support capabilities, it could face grid defection, and forego opportunities to significantly improve grid performance, productivity and system resiliency. 

Pace strongly supports Puerto Rico’s integration of DER, renewable energy, and coordinated microgrids to utilize the natural resources of the island and manage an electrical grid that supplies the power needed. In partnership with IEEFA, we submitted comments to PREC on microgrids.

Pace has also been heavily engaged in this work throughout the Northeast. We promote knowledge of high efficiency combined heat and power as a back bone to microgrids in our region as the US DOE TAP by evaluating site screening and successful case studies. This work dovetails with our solar coalition work where we advocate for streamlined policies that facilitate and reduce the cost of integrating distributed energy resources to the existing electrical grid. 

PECC panel: Carbon Taxes

PECC panel: Carbon Taxes

The idea of establishing a federal or state tax on carbon emissions is a concept gaining a lot of attention today. While everyone understands taxes, many don’t understand exactly how a tax on carbon would work, who would be impacted, and whether it would be effective in reducing climate-changing carbon emissions. Pace Energy and Climate Center, along with Sustainable Westchester Federated Conservationists of Westchester County, Citizens’ Climate Lobby New York State, and Citizens’ Climate Lobby Westchester, are hosting a forum to discuss the idea of a tax on carbon. Pace has secured a panel of national experts to discuss, and looks forward to having questions answered and ideas about carbon taxes discussed.

The Pace Energy and Climate Center panel discussion on carbon taxes:

Date: Monday, March 26, 2018

Time: 5:30pm-7:00pm

Location: Tudor Room, Preston Hall, Pace University Elisabeth Haub School of Law, 78 N. Broadway, White Plains, NY 10603.

In preparation of this discussion, Pace has assembled some helpful resources for basic knowledge about the carbon tax concept.

In its most simple form, a carbon tax is a fee levied by an agency of government on the production, transportation, or use of fossil fuels. Today, the price of fossil fuels and the products and services we get from fossil fuel use do not reflect the cost that carbon emissions impose on the climate and people. The idea behind a carbon tax is that if the price of things reflects the real cost, our purchase and use decisions will be more economical. Setting the right carbon tax and deciding which fuels or activities will be taxed are the first decisions that have to be made.

The next big question about carbon taxes is what to do with the money raised. Should the tax revenues go toward general government budgets? To offset the burden on consumers? To fund improvements and growth in clean energy technologies?

Below are listed a few resources that can serve as an introduction to the issue of carbon taxes. Some of these materials were prepared by advocates for carbon taxes.

Resources:

Vermont Law School Carbon Tax Primer

Carbon Tax Center

Northeast Regional Cap and Trade Initiative

Reuters on a National Carbon Tax

Carbon Fee and Dividend

Accounting for the Value of Energy Resiliency in Buildings

Accounting for the Value of Energy Resiliency in Buildings

by Thomas G. Bourgeois, Deputy Director

Hurricanes Harvey and Irma are fresh in our minds. We read of the homes, businesses, healthcare facilities the customers numbering in the millions who were without power. Although unpleasant for most, not having power, heating and cooling can be fatal for some.

In Hollywood Hills, Florida, New York Times reported deaths of 8 residents at The Rehabilitation Center, where air conditioning systems failed due to a power outage. This stands as a stark reminder of the importance of maintaining continuous energy services for certain vulnerable populations and for high priority services. When the power is out at hospitals, nursing homes, assisted and senior living, large multifamily and public housing complexes, there are few good options. One approach that has succeeded time and again in the past is an onsite, combined heat and power (CHP) system that has been constructed to run during grid outages.

Properly designed, configured, and operated combined heat and power (CHP) systems can provide power, heating and cooling to buildings during energy outages of extended duration, as was delivered during Super Storm Sandy. Pace Energy and Climate Center discusses in Powering Through Storms, natural gas (generally not affected by storms) powered CHP is capable of delivering energy services so that the site remains comfortable, habitable, and functional.

At businesses, campuses, healthcare centers, and multifamily complexes where energy demands are suited, well-designed CHP systems can be smart, cost saving investments. They offer a suite of benefits, well beyond cost savings, that are often overlooked. An important benefit of a CHP system is the resiliency the building and its occupants can depend on. Post Katrina,  Sandy, and now Post Harvey and Irma It’s time that decision makers account for the reliability that a CHP system offers them when making investments in buildings.

The resiliency value of CHP has been well documented in  “Combined Heat and Power: Enabling Resilient Energy Infrastructure for Critical Facilities” prepared for Oak Ridge National Labs 14 case studies from around the country describe the performance of CHP systems during emergency events. When disasters, like hurricanes Harvey and Irma, Sandy, Katrina, and others, strike we are all reminded of the enormous economic, personal, and social value of operating hardy buildings. The ability to withstand and recover from a storm is particularly important for critical infrastructure facilities, such as hospitals and wastewater treatment plants, or in residential complexes where vulnerable populations–the elderly, the infirm, and the very young—are best served by a “safe in place” strategy to the extent possible.

It would behoove anyone charged with making investments to value the resiliency of buildings, especially critical infrastructure. The investment in combined heat and power generates economic returns and environmental benefits over the long run. By also valuing building resiliency, CHP becomes an ever more attractive, yet far too often overlooked investment for a broad class of buildings.

RGGI States Announce Additional 30% Reductions in Emissions

RGGI States Announce Additional 30% Reductions in Emissions

The Regional Greenhouse Gas Initiative (RGGI) is the United States’ first market-based cap and trade mechanism to reduce emissions within the nine states that participate. RGGI only applies to power generators greater than 25MW of installed capacity, and membership is optional.

Announcement

The nine states in the Regional Greenhouse Gas Initiative (RGGI) reaffirmed their climate leadership by agreeing to a visionary plan to reduce power plant carbon emissions by an additional 30% by 2030. The plan includes program design changes that will increase the RGGI program’s effectiveness and help keep the RGGI states on track for meeting their 30% target.

These changes come at a critical moment. Many U.S. states are increasing emission reduction efforts to offset the impact of the federal government’s back peddling on climate action, and to challenge the Trump administration’s recent announcement of the intent to withdraw the U.S. from the Paris Agreement.

Program Mechanisms

The RGGI states agreed to a plan that includes an additional 30% reduction in the emissions cap by 2030. The plan also includes several key design changes that are expected to strengthen RGGI and make the 30% reduction attainable.

The first key change is the addition of an Emissions Containment Reserve (ECR), which sets a price-floor for emission allowances, and permanently retires allowances if the price-floor is triggered. The ECR, which will be implemented in 2021, certainly is a step in the right direction for addressing an oversupplied market. However, two of the RGGI states—Maine and New Hampshire—have indicated that they do not intend to implement an ECR.

The second key change is a full excess-banked-allowance adjustment. This adjustment will occur during the years 2021–2025, and will send a clear message that the RGGI states intend to prevent an oversupply of allowances from eroding the effectiveness of the RGGI program.

The third key change is a set of modifications to the Cost Containment Reserve (CCR). The CCR sets a price-ceiling which, if triggered, releases additional allowances into the market. The modifications to the CCR include both an increase in the price-ceiling and a reduction in the number of allowances released if the price-ceiling is triggered.

The true success of the RGGI states’ aggressive plan will likely result from the combined impact of the additional 30% cap decline and these three key design changes:

1.     The addition of an ECR, with a price-floor initially set at $6 in 2021, a price greater than the current auction clearing price, and set to be increased by 7% annually.

2.     The additional cap adjustments in the period 2021–2025 to address excess banked allowances.

3.     The modifications to the CCR, with a price-ceiling of $13 in 2021, which is set to be increased by 7% annually, and with a decrease in the number of allowances released upon a trigger.

The Details

The proposed cap for 2021, from which annual reductions will follow, is 75.15 MTco2. During the years 2021–2030, the cap will decline annually by 2.275 MTco2 allowances, resulting in a 2030 cap of 52.39 MTco2. The RGGI states also plan to address the excess banked allowances that have accumulated in the market. The states will revise the Model Rule to establish a formula for calculating the number of banked allowances in the market. The formula will be applied in 2021, and the emissions cap will be adjusted to account for the banked allowances during the period 2021–2025.

All states, except New Hampshire and Maine, plan to adopt an ECR that will permanently retire allowances from circulation if auction prices fall below the price-floor. The ECR will be implemented in 2021, and is structured to remove a quantity of allowances equivalent to 10% of that year’s base cap if it is triggered. The price floor for the ECR initially will be set at $6, and will be raised by 7% annually.

For the CCR, the price-ceiling will be set at $13 starting in 2021, and will also increase by 7% annually. This is a significant increase over both the current trigger price of $10, and current 2.5% rate of increase in the trigger price. The number of allowances in the CCR also is significantly reduced under the RGGI state’s aggressive plan. Beginning in 2021, the number of allowances in the CCR will be limited to 10% of the RGGI cap for that year. Based on the anticipated cap for 2021, the CCR will contain approximately 7.515 million allowances for potential release in 2021. This is a significant reduction from the current level of 10 million allowances in the CCR for potential release annually.

These program design changes are also important to protect another of RGGI’s successes—the reinvestment of proceeds generated from allowance auctions. To date, RGGI auctions have generated over $2.7B in revenue, almost half of which has been invested in energy efficiency, renewable energy development, and other beneficial programs. Allowance auction prices directly impact the amount of revenue available for these reinvestment programs (see Figure 1). The RGGI program design changes will help to prevent excessive allowances from accumulating in the market and should result in an increase in allowance prices over time, which should in turn increase the allowance proceeds available for reinvestment, even as the number of allowances available for auction decline.

Figure 1: Revenues from RGGI auctions have generated upwards of $2.7B in funds for energy efficiency and renewable energy development in participating states. At its peak, RGGI generated over $152M to benefit states in a single auction.

Final Thoughts

The program modifications are certainly ambitious, and are being celebrated as a win by many of the environmental advocates, including the Natural Resources Defense Council (NRDC). Since its inception, RGGI’s goal has always been to reduce power plant emissions within the region, and these proposed changes should add to the program’s ongoing success if adopted. The proposal is already being met with significant praise from the heads of state agencies such as New York’s Department of Environmental Conservation and the Massachusetts Department of Environmental Protection.

Looking ahead, several challenges await the program changes, and not all of the RGGI states (Maine & New Hampshire) have tendered their full support for all of the changes. Theoretically, the changes will help market forces drive up the price of allowances, creating an environment that drives investment towards renewable energy and efficiency. The concern is what the responses will be from compliance entities regarding how they procure their electricity.

The New York Public Service Commission Modifies its Rule on Membership for Community Distributed Generation Projects.

The New York Public Service Commission recently issued an order modifying the Community Distributed Generation (CDG) membership requirements. As previously reported on our January 26, 2017 blog post, the order establishing a Community Distributed Generation (CDG) program stipulated a ten-member minimum for properties located on projects with multiple residential units as one of its requirements. The Petitioners argued that this requirement was in essence a barrier to the adoption of solar, and alienated members of the community that lived in multi-unit residential or mixed-use buildings with fewer than ten metered tenants from benefiting from the CDG program.

The Public Service Commission found in its ruling that, “removing the minimum ten membership requirement for on-site CDG installations on multi-unit housing is in the public interest.”

The Pace Energy and Climate Center supported the Petition to waive the ten-member minimum requirement, and highlighted the impediment issues the membership requirement would cause to the Community Distributed Generation (CDG) program.

Pace applauds the Public Service Commission for its decision, and we believe that this decision opens the gateway for low to moderate income households to have access to clean and affordable energy. Overall, this synthesizes with the vision of New York state in securing a sustainable future for all.

The new rule came into effect on April 1, 2017.

New York Public Service Commission “REVs” Up Utility Reform in Consolidated Edison Rate Case

New York Public Service Commission “REVs” Up Utility Reform in Consolidated Edison Rate Case

  • New York Public Service Commission adopted a three-year rate plan for Consolidated Edison, including several key Reforming the Energy Vision initiatives.
  • The Pace Energy and Climate Center and Earthjustice partnered on our fifth New York rate case and scored a number of REV wins, including on standby rate reforms, energy efficiency, and REV-aligned rate design.
  • This is the first “post-REV” rate case and is a significant milestone in New York’s path to grid modernization.

The New York Public Service Commission adopted a three-year rate plan for Consolidated Edison Company of New York on Tuesday, marking the first rate plan the Commission has approved following its landmark Order Adopting a Ratemaking and Utility Revenue Model Policy Framework (the “Track Two Order”), which laid the groundwork for many of the Reforming the Energy Vision’s key principles.

Earthjustice and the Pace Energy and Climate Center (“Pace”) partnered in the case and pushed for many of the REV-aligned reforms approved by the Commission. Several Pace staff and law student interns worked on the case along with staff attorneys from Earthjustice. Pace and Earthjustice played a key role in securing a number of wins for advancing fair rates, increasing deployment of energy efficiency, advancing climate responsibility, and growing markets for distributed energy resources (“DER”) such as energy efficiency, energy management, distributed generation, electric vehicles, and other technologies and services.

“Our partnership with Earthjustice enabled us to advance strategic objectives of just and reasonable rates for ConEd customers as well as substantial progress toward realizing the vision of the REV process for greater deployment of DER,” said Karl R. Rábago, Pace executive director and expert witness in the case.

The months-long settlement negotiations resulted in a Joint Proposal, filed on September 19, 2016, with more than 20 signatories, including Pace, the City of New York, Natural Resources Defense Council, Environmental Defense Fund, distributed generation and real estate developers, and others.

The rate case is a significant milestone in the ongoing REV process. As Commission Chair Audrey Zibelman noted prior to voting in support of the Joint Proposal, this case represents “a significant step toward modernizing the electric system and changing the utility business model.”

Five of Pace’s subject matter experts—Executive Director Karl Rábago, Deputy Director Tom Bourgeois, Senior Energy Policy Associate Dan Leonhardt, Energy and Climate Law Advisor Jordan Gerow, and Professor Michael Gerrard, Director of Columbia University’s Sabin Center for Climate Change Law—testified on a number of REV concepts, including much-needed standby rate reforms, developing metrics to measure AMI program performance, best practices for microgrid development, and innovative, REV-aligned cost allocation to capture the costs and benefits of Con Edison’s new role as distribution system platform provider.

Among the key REV “wins” approved by the Commission are:

  • Standby Reform: An overhaul of Con Ed’s standby rates, as required under the Track Two Order, including a revamped Reliability Credit with more stringent NOx emissions standards, and a Standby Rate Pilot that includes provisions to incentivize more efficient combined heat and power (CHP) units;
  • Energy Efficiency, System Peak Efficiency, and Electric Vehicles Programs: Con Edison’s proposed energy efficiency budgets and targets go beyond what the Company is currently required to achieve, and are projected to yield more than 300 gigawatt-hours of savings per year, equivalent to the energy needed to serve over 40,000 homes in New York State. The system efficiency program would add an additional 22 GWh of energy savings and provide 49 megawatts of system peak reduction. The energy and system peak efficiency programs also include proposed Earnings Adjustment Mechanisms—novel mechanisms established under the Track Two Order for utilities to generate new revenue streams and accomplish energy policy goals. These savings are especially important in light of the recently announced agreement to close the Indian Point nuclear plant.
  • Electric Vehicles: A collaborative process will be established to consider developing new rate structures, incentives or pilot programs for electric vehicles.
  • Climate Change Vulnerability Studies: The agreement, if adopted, would authorize the Company to spend up to $4 million on completing its Climate Change Vulnerability Study by 2019.
  • Advanced Metering Infrastructure (“AMI”) Metrics: Done right, AMI can help to grow DER and ancillary services markets, and empower customers to manage their home and business energy use. The Commission approved Con Ed’s AMI Business Plan earlier this year, and as the Company moves forward, its AMI program will be subject to ongoing measurement and assessment to ensure that the program is on the right track.
  • Rate design reforms: The proposed agreement inches Con Ed toward a more granular cost functionalization and allocation model, which is critical to helping the Company move from the one-way energy delivery and cost recovery of the past and toward its new role as distributed system platform provider.
  • The Commission also separately approved a related Targeted Demand Management program that will incentivize the Company to pursue “non-wires alternatives” projects, like the Brooklyn-Queens Demand Management project, thanks to a split incentive between customers and shareholders. Lessons learned in this program will be vital in addressing any supply gap created by the closure of Indian Point.

This is Earthjustice and Pace’s fifth partnership on a New York rate case, following the successful completion of settlement agreements in Central Hudson and Orange & Rockland Utilities’ 2014 rate cases, and Con Edison and New York State Electric and Gas / Rochester Gas & Electric’s 2015 rate cases.

Three other New York investor-owned utilities could file rate cases in 2017: National Grid, Orange & Rockland Utilities, and Central Hudson Gas and Electric.

Pace and Earthjustice look forward to tracking those filings and continuing to push for fair rates, clean energy and climate responsibility, and REV-aligned market reforms.

Earthjustice Associate Attorney Chinyere Osuala says: “In a time when President Trump’s clean energy goals are ambiguous at best, states are taking charge. New York is proving itself to be a leader in clean energy by modernizing the electric grid. This rate plan advances that vision for New York City and Westchester residents and their families.”