Archive

An optimization method for designing time-of-use rates, replacing a regulator’s sense of reasonableness with rates that minimize the gap between TOU and hourly costs — and that let competing designs be compared directly.

A production-cost and capacity-expansion simulation of Clean Peak Standards on a New England-like system. Depending on formulation, CPS raise system costs while cutting emissions barely or not at all — a renewable portfolio standard buys five to ten times more abatement per dollar.

Behind-the-meter batteries run to minimize bills tend to raise grid emissions. Pairing five years of ISO-NE and PJM data with fifteen commercial load profiles, the paper shows how much of that effect retail rate design can undo — in PJM the cleanest design induces half the emissions of the dirtiest.

Energy Policy, vol. 129, pp. 481–490.

Simulates a 1 MW / 4 MWh battery under three operating modes across sixteen systems ranging from 17% to 81% renewable energy, to find where storage stops adding carbon. Breakeven arrives between roughly 17% and 40% renewables, depending on how the battery is run.

M.S. thesis; co-winner of the program’s best-thesis award.

Part of the Full Cost of Electricity study: an accounting of state subsidies, mandates and tax preferences across generation technologies, and what they add per unit of energy produced.

With C.W. King, G. Gülen, J.S. Dyer, D. Spence and R. Baldick. UTEI/2018-1-1.

The federal companion to the state-level study: tax credits, loan guarantees and direct spending traced by technology and normalized per MWh, so support can be compared across resources rather than headline dollars.

With G. Gülen, J.S. Dyer, D. Spence and C.W. King. UTEI/2016-11-3.

Supporting affidavit in LS Power’s March 2024 complaint against PJM and its Independent Market Monitor over the treatment of opportunity-cost adders in energy market offers. FERC granted the complaint in part in August 2025, including key findings related to the need for transparency.

An amendment to the offer cap in the Forward Reserve Market, brought during the transition to the day-ahead ancillary services design that ultimately replaced it. The original cap was $9,000/MW-month; the ISO proposed lowering it to $6,300, I proposed $7,200, and the ISO filed an in-between $7,100 — approved by FERC in ER24-1245.

For LS Power Development.

Comments — just short of a protest — on ISO-NE’s proposal to establish a jointly optimized day-ahead market for energy and ancillary services, pressing the challenges the design creates for fast and flexible resources. FERC accepted the filing, effective March 1, 2025.

Amendments to the first phase of ISO-NE’s capacity market overhaul — the move from a three-year-forward annual auction to a prompt auction with a new resource deactivation process — pressed over four monthly meetings: expeditious deactivation for non-reliability resources, market-relevant COPT values for the prompt-auction transition, extended outages, the three-year rule, and state-jurisdictional interconnection agreements. Changes to resource forced-retirement rules were amended in a separate proceeding (ER26-1956).

For LS Power Development.

A proposed mechanism for resources being repowered to exit existing capacity commitments, so rebuilding a plant does not require carrying an obligation the old configuration can no longer meet. Failed at the Participants Committee.

For LS Power Development.

A year-long campaign of modeling work (largely) arguing that gas-only resources should be accredited on unit-specific fuel availability, and showing how that could be built into ISO-NE’s accreditation project — plus a separate set of amendments on the treatment of atypical equipment outages. ISO-NE halted RCA, and these issues withered on the vine.

For LS Power Development.

Protest of a complaint arguing that ISO-NE unduly favors gas-only generators by accrediting them as if fuel were always available. FERC dismissed the complaint in February 2023, deferring to the region’s accreditation stakeholder process.

Alternative estimates of the energy-and-ancillary-services offset in the offer review trigger price reset — how much market revenue a new storage project could realistically expect to earn, and therefore the offer floor it faces entering the capacity auction. Three presentations and a memo to the NEPOOL Markets Committee through fall 2020, then a supporting affidavit filed with the NEPOOL-approved proposal at FERC. FERC accepted the update for FCA 15 in June 2021.

For the Massachusetts Attorney General’s Office.

Two rounds of comments in FERC’s forums on New England winter reliability, where cold-weather gas supply constraints repeatedly put the regional grid at risk — including one set of in-person testimony at a commissioner-led conference in Maine.

From the AGO’s Chapter 3 preliminary proposal (with London Economics International) through ISO-NE’s proposed day-ahead ancillary products for winter energy security, and two amendments pressed over six months of committee meetings to better balance energy security, price formation and consumer cost: eliminate the Replacement Energy Reserve product, and add a look-back provision to the settlement of the new day-ahead reserve products. NEPOOL adopted variations of both; FERC ultimately rejected ESI itself (ER20-1567), and the design questions returned — and were resolved — in DASI.

For the Massachusetts Attorney General’s Office; amendments with C. Belew.

Affidavit on ISO-NE’s interim winter program, the Inventoried Energy Program, which paid resources to hold energy inventory on cold days, and whether payments from the IEP would buy reliability the region was not already getting. FERC accepted the program, which ran for the 2023/24 and 2024/25 winters.

Direct and surrebuttal testimony on how the company calculated marginal distribution costs — the figures that drive rate design and the economics of gas system expansion.

Report on an October 2019 symposium convening market designers, regulators and states on what wholesale markets should look like as the region decarbonizes — paired with an internal teach-in explaining ISO-NE, NEPOOL and the wholesale markets from first principles for lawyers and analysts new to the region.

Report with M. Hoffer, R. Tepper and the Regulatory Assistance Project.

Technical-session analysis of what EV time-of-use rates are actually worth to customers and the system, and how design choices divide those savings.

For the Massachusetts Attorney General’s Office.

The triennial study that sets the avoided-cost values New England program administrators use to screen energy efficiency investments. Worked on the 2013 and 2018 editions of AESC.

With Synapse Energy Economics and Resource Insight.

Review of the utility’s compliance filing on what customers declining a smart meter would be charged, and whether the charge reflected real avoidable costs.

With P. Chernick, for the Nova Scotia Consumer Advocate.

Review of the cooperative’s claim that regional haze controls at its Apache coal units were unaffordable, in EPA’s rulemaking on the Arizona plan.

With P. Chernick, for the Sierra Club.