photo courtesy of the Sierra Club
Virginia won’t enter the nine-state carbon emissions trading program known as the Regional Greenhouse Gas Initiative until 2020 under regulations being finalized by the state, but debate about how much it might cost utility ratepayers is already heating up.
Estimates range from little or no cost — or even a cost savings — to as high as $12 per month for the average household, depending on who is doing the calculations and the assumptions they make.
An Associated Press article reports that State Corporation Commission staff testified before a legislative committee that joining RGGI via the Virginia Coastal Protection Act, SB 1666 and HB 2735, would cost Virginia households an added $7-12 per month. The Northam administration disputed the SCC figure, saying the true cost would be about a dollar per month.
Republicans killed the bill in both the Senate and House committees that day.
A few days later, the anti-RGGI bill, HB 2611 (Poindexter), sailed through the House on a party-line vote. It would prevent Virginia from participating in RGGI or any other carbon-reduction regimen. If it also passes the Senate in coming weeks, it faces certain veto by the governor.
So is joining RGGI an inexpensive way to incentivize utilities to save energy and lower carbon emissions, or will it pile costs onto customers?
RGGI, for those of you who need a quick brush-up on your carbon policies, is a cooperative, market-based effort that has been running in New England and the Mid-Atlantic states as far south as Maryland for the past decade.
It works by auctioning carbon pollution allowances to major emitters, gradually ratcheting down the number of allowances made available each year to incentivize conservation and the use of lower-carbon fuels. States use the money they raise to fund energy efficiency, community solar, weatherization and other programs, often focusing especially on low-income residents.
First things first: RGGI works.
According to a 2018 report by Analysis Group, the RGGI region has met its targets, and benefited economically as well:
“Over three years (2015-2017), the RGGI program led to $1.4 billion (net present value) of net positive economic activity in the nine-state region,” the report says. “Each RGGI state’s electricity consumers and local economy also experienced net benefits from the RGGI program. When spread across the region’s population, these economic impacts amount to nearly $34 in net positive value added per capita.”
Virginia’s carbon reduction plan, now in the final stages of drafting at DEQ, will have Virginia participate in the RGGI auctions but not raise money from auctioning allowances.
Beginning in 2020, RGGI will add Virginia carbon emissions (28 million tons, the baseline DEQ has chosen) to the total for the existing members (56 million tons), and our utilities will bid for and trade allowances with the utilities in the other nine states.
But unlike the existing RGGI states, under DEQ’s plan Virginia will distribute its share of carbon allowances to our utilities at no cost, based on their previous year’s electricity sales. Utilities will sell the allowances into the RGGI auction bucket and buy back as many as they need. Initially, at least, the effect on ratepayers should be pretty much a wash.
Chris Bast, chief deputy at the Virginia Department of Environmental Quality said DEQ’s modeling program estimated rates would increase about 1 percent as a result of the new regulations. That’s a much lower figure than the $7 per month the SCC estimated the program would cost even with free allowances.
State Corporation Commission spokesman Ken Schrad said the DEQ “has understated the price of carbon emissions and understated Dominion’s cost of money for future capital investments (borrowed from lenders or invested by shareholders).”
“DEQ modeled Dominion as if it was a deregulated utility in a competitive market,” Schrad said. “Dominion’s fossil fuel generating units must be paid for in rates regardless of whether they are generating electricity under its vertically integrated structure.”
Bast takes issue with this. “I don’t know where the SCC got its numbers,” Bast told me. “Many folks, including the DEQ, have done extensive modeling to determine the environmental and economic impacts of the rule. That modeling is part of the public record and is part of the extensive public process that has gone into crafting this regulation. The SCC’s analysis is an outlier by several orders of magnitude – nearly 600%. The SCC has not provided any comment about ratepayer impact during any of our regulatory proceedings.
“We’re simply asking the SCC to show their work. But, to date, they have refused to provide us with the analysis that supports their conclusions.”
Bast says DEQ has not modeled what the program would cost if utilities had to pay for allowances, as contemplated under the Coastal Protection Act. Paying for allowances, according to the SCC, could drive costs up by an additional $5 per month.
This is a moot point, for now, since the Coastal Protection Act did not pass. But advocates believe that auctioning allowances offers an opportunity to raise funds to invest in energy efficiency and climate programs, so the idea remains on everyone’s radar for next year.
How RGGI works:
Under the Coastal Protection Act, auction proceeds would go into the state’s coffers to fund energy efficiency and resiliency programs that benefit the public. Utilities would be able to recover the costs of buying allowances from their customers, so there would be more impact on rates than there would be if allowances are free.
The Coastal Protection Act takes an extra step and actually requires investor-owned utilities to build wind and solar to achieve at least 50 percent of the required emissions reduction. If that amount were to exceed what they planned to build anyway, it would mean more costs paid for by customers—though maybe not a lot, if it speeds up the retirement of old fossil fuel plants that ought to close anyway.
RGGI reduces carbon emissions over time by gradually decreasing the number of auction allowances available in the region year after year. As the carbon cap tightens, either allowances become more expensive, or utilities reduce emissions, or both.
So far the RGGI states have succeeded in reducing emissions without higher allowance prices. They have done this in large part by closing coal plants and investing in energy efficiency and renewable energy, including programs paid for by auctioning the carbon emissions allowances.
Most RGGI states also have mandates for efficiency and renewable energy, which Virginia lacks. (In spite of the hoopla around it, last year’s “grid mod” bill did not require utilities to achieve any specific efficiency or renewable energy outcomes.) The combined effect of all these actions is that the prices paid for auction allowances in RGGI have stayed low.
According to the Analysis Group, consumers in RGGI states have benefited:
“On the one hand, the inclusion of the cost of CO2 allowances in wholesale prices tends to increase wholesale electricity prices in the RGGI region at the beginning of the 2015-2017 period,” the report says.
“But these near-term impacts are more than offset during these years and beyond, because the states invest a substantial amount of the RGGI auction proceeds on energy efficiency programs that reduce overall electricity consumption and on renewable energy projects that reduce the use of higher-priced power plants. Consumers gain because their overall electricity bills go down.
“Since RGGI’s commencement in 2009, energy and dollar savings resulting from all states’ investments in energy efficiency and renewable energy has more than offset the wholesale market price increases associated with inclusion of allowance costs in market bids.”
Virginia is as well-positioned as any of the RGGI states to meet the carbon-reduction goals.
Utilities can reduce energy demand through energy efficiency, resulting in less need for carbon-emitting fuel to be burned. They can also replace coal-fired generation with power from gas (with about half the CO2 of coal) or renewables (zero C02 for wind, water and solar; biomass has CO2 emissions as high as coal, but decision-makers pretend it’s carbon neutral).
Our nuclear plants, which provide a big chunk of Virginia’s electricity, are already operating at full capacity, and that’s not expected to change.
Intuitively, the solutions wouldn’t be expected to cost very much. Some of Virginia’s coal plants aren’t running very much these days anyway, putting them precariously close to the point where it is cheaper to close them than keep paying to have them available. As for alternatives, Dominion says solar is the cheapest form of new energy.
And energy efficiency is, famously, the lowest-cost energy resource, and vastly underutilized in Virginia.
In fact, projections have Dominion coming in under the RGGI cap for at least several years, putting our utilities in the happy (for them) position of possibly making money in the auctions.
But that doesn’t quite settle the matter.
There is one other consideration that could affect rates: Virginia utilities participate in the regional transmission organization known as PJM, which runs the wholesale power market. Anything that makes Virginia power more expensive makes it less attractive to the market.
That is surely part of the SCC staff’s concern.
To understand this dynamic, I consulted economist Bill Shobe, a professor at the Center for Economic and Policy Studies at the Weldon Cooper Center for Public Service at the University of Virginia, who studies carbon markets.
Shobe said that if Virginia utilities get CO2 allowances for free based on their previous year’s electricity generation, as the DEQ plan calls for, there should be no impact on their power plants’ competitiveness in PJM. The cost to customers would be little or nothing.
But if a coal or gas plant has to add the cost of CO2 allowances to its price of power, as happens in other RGGI states, power plants from non-RGGI states that don’t have to charge for CO2 will have a price advantage.
Shobe said if a Virginia utility adds the cost of CO2 allowances to the price of power from its own fossil fuel plants, those plants won’t run as much. Even the utility itself might buy cheaper wholesale power rather than run its own plants. Worse, the imported power could be higher in CO2 than the Virginia power it displaces, a problem known as “leakage.”
Dominion Energy Virginia’s 2018 Integrated Resource Plan, a document that forecasts how the utility will meet electric demand, predicted that if Virginia joined RGGI, its four big gas plants would run only an average of 64 percent of the time in 2025, compared to 79 percent in a scenario with no carbon constraints.
Dominion also claimed the cheaper imported power would come with such a higher carbon footprint than the power it was replacing that the whole deal would be counterproductive as a CO2 reduction strategy.
Skeptics should note that Dominion didn’t report the assumptions behind the modeling. Even its consultant, ICF, included a disclaimer that it was using the information Dominion gave it but “makes no assurances as to the accuracy of any such information or any conclusions based thereon.”
It’s also not clear that Dominion recognized any difference between getting free allowances and having to pay for them.
Shobe explained that Dominion’s modeling program didn’t account for DEQ’s use of “output-based allocation”— that is, distributing carbon allowances for free based on a utility’s generation in the previous year. This approach, said Shobe, incentivizes the utility to keep generating as much zero- or low-carbon electricity as it can so it will get as many allowances the next year as possible, and it will use its allowances to keep its own power competitive with imports.
The modeling that ICF did for Dominion, say Shobe, “treats all allowances as if they are sold at auction. Period. They don’t even attempt to model free allowances much less output-based allocation.”
With free allowances, customer costs should be minimal.
What if we auction the allowances?
Shobe said auctioning allowances instead of distributing them for free would make the power from Virginia’s fossil fuel plants less competitive in the PJM market. Yet customers will still have to pay for the capital cost of these huge gas plants that the SCC itself foolishly allowed Dominion to build, even if the power they generate is less competitive in PJM.
(“Foolishly” is obviously my term for it. The SCC not only doesn’t admit it did anything wrong, it rejected Dominion’s IRP in part because the company didn’t propose building yet another giant gas plant.)
The SCC’s high-end estimate seems to be based on this concern, but its numbers are much higher than even Dominion’s.
Dominion’s IRP estimated that joining RGGI would “cost Virginia customers about $530 million over the period 2020 to 2030,” or $53 million per year. The IRP says the impact would be about $3.50-$5 per month for residential customers, depending on the approach taken.
Even that estimate has to be taken with a bucket of salt. As the SCC staff noted at the time, Dominion overestimated the costs of joining RGGI by using overly high demand projections and failing to assume any decrease in demand from the hundreds of millions of dollars in efficiency programs the utility is required to design.
Obviously, those programs will also lower carbon emissions, helping Virginia meet the RGGI targets—as will building the solar energy envisioned by the grid mod bill.
So how the SCC staff has now come up with cost estimates even higher than Dominion’s is a head-scratcher. Nothing in the Coastal Protection Act appears to add costs beyond what Dominion knew about for its IRP.
This debate is surely not over.
We hope DEQ and the SCC will come together on a shared set of facts and assumptions, but meanwhile it is worth noting two points.
One is that even Dominion agrees some sort of carbon regulation at the federal level is likely eventually, even if it doesn’t happen under President Donald Trump’s administration.
Starting to shrink our carbon footprint now instead of later is going to save us money, even apart from its climate and health benefits.
The other is that the RGGI approach brings proven economic benefits to customers. As the Analysis Group report showed, customers in RGGI states actually saw lower bills in spite of higher rates because of the investments in energy efficiency.
If that happens in Virginia, joining RGGI will actually put more money in the pockets of customers.
A version of this article first appeared in the Virginia Mercury on February 6, 2019.