| Renewable Energy Portfolios Standards and Transmission 
    Reliability, Part IV 
 
 Location: New York
 Author: George Campbell
 Date: Friday, February 1, 2008
 Most economists believe that they can solve any problem with the right mix 
    of incentives. They dream them up and implement them, study their results, 
    and then reshape them. Many economists believe the world has not yet 
    invented a problem that cannot be fixed if given a free hand to design the 
    proper incentive scheme. The solution may not always be pretty—often 
    involving coercion—but the original problem can be fixed. If demand response 
    is to play a large role in solving renewable portfolio standard's (RPS) 
    reliability problems, finding the right mix needs to take place (review my 
    first two articles in this series on RPS reliability problems Part I & Part 
    II.
 
 In Part III of this series, I outline the three broad categories of 
    incentives that can be used to solve the demand response (DR) problem: 
    Financial Incentives, Moral Incentives and Mandatory Incentives. Given the 
    right mix of these three incentive types, I believe that the DR problem can 
    also be solved. To help understand how the three interact, I am going to use 
    an example from the international best selling book, Freakonomics, which is 
    a summary of some of University of Chicago economist Steven Levitt's 
    research on incentives. While the whole book provides a framework on how to 
    frame questions and seek answers to solve this problem, I am going to use 
    his example of an Israeli daycare center.
 
 Parents picking up children late have always been a problem of daycare 
    centers. A pair of Israeli economists who heard of this common dilemma 
    offered a solution: charge an additional fee to the tardy parents. The 
    economists decided to test their solution by conducting a study of ten 
    daycare centers in Haifa, Israel. The study lasted twenty weeks, but the 
    additional fee was not introduced immediately. For the first four weeks, the 
    economists simply kept track of the number of parents who came late; there 
    were, on average, eight late pickups per week per daycare center. In the 
    fifth week, the fee was enacted. It was announced that any parent arriving 
    more than ten minutes late would pay $3 per child for each incident. The fee 
    would be added to the parents' monthly bill, which was roughly $380. After 
    the new fee was enacted, the number of late pickups promptly went up. Before 
    long there were twenty late pickups per week, more than double the original 
    average. The incentive had plainly backfired. So, what was wrong with the 
    incentive at the Israeli day-care centers? The $3 fee was simply too small. 
    For that price, a parent with one child could afford to be late every day 
    and only pay an extra $60 each month—just one-sixth of the base fee. The 
    problem with the day-care center late fee was it substituted a Financial 
    Incentive of $3 for a Moral Incentive (the guilt that parents were supposed 
    to feel when they came late). For just a few dollars each day, parents could 
    buy off their guilt. Furthermore, the small size of the fee sent a signal to 
    the parents that late pickups weren't such a big problem. All of us know how 
    the day care markets of the world solved this problem as we have experienced 
    parents abruptly leaving meetings at the end of the day to avoid very high 
    late fees. I have heard of some late fees that are so high and parents with 
    few other options that they go from being a Financial Incentive to a de 
    facto Mandatory Incentive.
 
 Any incentive structure is a trade-off of these three types of incentives. 
    If DR is to grow in the United States, it will require the right complement 
    of Financial, Moral, and Mandatory Incentives. Financial Incentives have 
    been the mainstay of the DR incentive structure to date and will continue to 
    be. Every time a transmission operator or distribution utility calls for 
    voluntary load curtailment during peak times and customers curtail load, a 
    Moral Incentives is used. However, Mandatory Incentives have not been used 
    extensively and if DR is to significantly expand in its utilization, 
    understanding how to use it in compliment with the first two will need to 
    take place.
 
 Examples of Mandatory Incentives in the electric utility industry are 
    numerous. At the Federal level in the last quarter of a century they can be 
    viewed as major segments starting with the Public Utility Regulatory Policy 
    Act (PURPA) of 1978 and the Energy Policy Acts of 1992 and 2005. These laws 
    set in motion the unbundling of generation as a monopoly and opened the 
    transmission system to bulk power sales. Most states have also implemented 
    Mandatory Incentives for a number of competitive market measures and to 
    solve environmental and social issues, such as recent renewable portfolio 
    standards that have been implemented in twenty five states. At the federal 
    level, DR has had no Mandatory Incentives implemented. This is probably the 
    result of federal law delegating retail electric oversight to state 
    authority and the FERC not regulating retail sales. At the State level, I 
    can only identify a few DR Mandatory Incentives and most of them could be 
    considered a secondary effect. The one I have written about most is the 
    requiring of default service for large C&I customers based on the wholesale 
    electric spot market.
 
 So, what are the ranges of options for Mandatory DR Incentives? I group them 
    into the following:
 
 * Compulsatory Customer Reductions: Requires customers to reduce a certain 
    amount of electric usage at the request of an entity with penalizing 
    authority for non compliance.
 * Obligatory End-Use Control: Requires certain end usages of electricity to 
    be used during off peak times.
 * Obligatory Facility Equipment: Requires retail customers to install 
    equipment in their facilities that has the capability to support DR.
 * Distribution Utility Requirements: Requires Retail Electric Distribution 
    utilities to implement measures that promote the expansion of DR and will 
    complement their Financial or Moral DR Incentives.
 
 To implement Compulsatory Customer Reductions for retail electric users will 
    entail the following:
 
 1. Metering capable of measuring short-term energy consumption intervals;
 2. Communication systems to notify customers of curtailment requirements; 
    and,
 3. A regulatory agency to establish customer specific curtailment amounts, 
    set penalties and enforce non-compliance.
 
 The metering infrastructure for measurement of a Compulsatory Customer 
    Reduction incentive is already in place for a large segment of the US's 
    commercial and industrial (C&I) customers. There are also many options for 
    the DR communication technology. Both of these first two infrastructure 
    needs are also needed to manage existing Financial DR Incentives type 
    programs and would be easy to transfer to Compulsatory Customer Reductions. 
    Enforcement of a mandatory requirement to curtail load would be very similar 
    to enforcement of customers on present voluntary interruptible programs. The 
    hurdle to a mandatory reduction requirement is that a central planning 
    process will be needed to determine how much every customer will curtail and 
    for what types of transmission reliability needs will trigger the 
    curtailment. Because individual retail customers have a broad range of 
    compliance cost and curtailment potential, Compulsatory Customer Reductions 
    will require the central administration function to allocate different 
    curtailment requirements towards different customers to ensure that there 
    are economic efficiency gains. It is my opinion that Mandatory Incentives of 
    this type have a high potential to decreased economic efficiency. They 
    should be one of the last to be considered. Before it is implemented it 
    should be studied under controlled conditions. Also other types of Mandatory 
    Incentives that do not have a high potential to decrease economic efficiency 
    should be implemented first.
 
 Obligatory End-Use Control requires certain end usages of electricity to 
    incorporate DR. It has the potential to increase DR, especially in areas 
    which already have existing building inspectors that are already enforcing 
    other codes. For example, a building code would only allow controlled water 
    heating and the customer could put in dual fuel systems or a larger storage 
    tank so that there would not be deterioration in service quality. Another 
    example is the plug-in hybrid car and only allowing charging under a DR 
    controlled electric charge.
 
 An example of a DR Obligatory Facility Equipment requirement for customer 
    facilities is an Energy Management Systems (EMS) to control heating, 
    ventilating, air conditioning and refrigeration equipment for residential, 
    commercial and industrial buildings. This building requirement could also 
    accomplish another social goal of energy efficiency. These last two types of 
    Mandatory DR Incentives should be evaluated in conjunction with Financial 
    and Moral DR Incentives. In addition they can be incorporated into broader 
    incentive structures to improve energy efficiency. In addition there are 
    many types of controls for residential appliance controls that could be 
    installed as part of standard features.
 
 There are many examples of Distribution Utility Requirements. As part of an 
    IRP process, State Regulatory Commissions can require rebates for an EMS or 
    other DR enabling equipment. However, the one I believe would be most 
    effective is to require all large C&I customers to take default service 
    under rates that represent the wholesale electric spot energy and capacity 
    prices. (See Part III of this series).
 
 To help solve the reliability problems that RPS will create will require 
    getting the "right mix" of these three incentive types. The "right mix" will 
    always require fine tuning and will also be different by region and will 
    change as the regional portfolio of supply side resources change as well as 
    customer end-use technology evolves. The solution is definitely not static. 
    My goal in this series is to start laying out the framework to identify the 
    range of DR incentive options.
 
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