Energy Storage Value and Adoption Analysis

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#1The Economic Potential for Energy Storage in Nevada PRESENTED TO Nevada Governor's Office of Energy Public Utilities Commission of Nevada PRESENTED BY Ryan Hledik Roger Lueken Judy Chang Johannes Pfeifenberger Jeremy Vollen John Imon Pedtke October 15, 2018 THE Brattle GROUP Copyright © 2018 The Brattle Group, Inc.#2Disclaimer This report was prepared for Public Utilities Commission of Nevada (PUCN) and the Nevada Governor's Office of Energy (GOE) based on work supported by the Nevada Governor's Office of Energy, and the Department of Energy, Office of Energy Efficiency and Renewable Energy (EERE), under Award Number DE-EE0006992. It is intended to be read and used as a whole and not in parts; it reflects the analyses and opinions of the authors and does not necessarily reflect those of The Brattle Group's clients or other consultants. The authors would like to acknowledge the valuable collaboration and insights of Donald Lomoljo and John Candelaria (PUCN), Angela Dykema (GOE), Patrick Balducci and Jeremy Twitchell (Pacific Northwest National Laboratory), and the contributions of NV Energy staff in providing necessary system data. We would also like to thank Brattle Group colleagues for supporting the preparation of this report, including Jesse Cohen for modeling of behind-the-meeting storage applications. While this report was prepared as an account of work sponsored by an agency of the United States Government, neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof. There are no third party beneficiaries with respect to this report, and The Brattle Group does not accept any liability to any third party in respect of the contents of this report or any actions taken or decisions made as a consequence of the information set forth herein. brattle.com 2#3Agenda Study Purpose and Scope Approach to Estimating Storage Costs and Benefits Evaluation of Key Storage Value Drivers Aggregate System-Wide Benefits of Storage Behind-the-Meter Applications Comparison to Other Storage Potential Studies Study Conclusions brattle.com 3#4Study Purpose and Scope Study Purpose: "Provide information to be used by the Public Utilities Commission of Nevada (PUCN) in determining whether procurement targets for energy storage systems should be set in Nevada pursuant to Senate Bill (SB) 204 (2017), and at what level" Scope: - Evaluate benefits of storage across several uses Identify storage use cases, including behind-the-meter at customer sites, on the distribution system, and on the transmission system Evaluate the global storage industry landscape, including trends in costs - Estimate cost-effective storage potential for Nevada for 2020 and 2030 brattle.com 4#5Approach to Estimating Storage Costs and Benefits brattle.com 5#6Approach Approach and Key Value Drivers Evaluated We utilize Brattle's bSTORE model to evaluate the key drivers of storage value change as increasing amounts of storage is added to Nevada. We quantify four key value drivers: - - - Production Cost Savings: Changes in NV Energy's cost of providing energy and ancillary services Avoided Capacity Investments: Reduction in generation capacity needed to meet peak load Deferred T&D Investment: Value of deploying storage to defer upcoming T&D investments Avoided Distribution Outages: Reductions in load shedding by locating storage on certain distribution feeders Our approach accounts for likely limitations in the ability to "stack" these values Location limitations: We assumed that storage can be deployed at certain distribution grid locations either to defer T&D investment or avoid distribution outages, but we have conservatively assumed that both value cannot be captured simultaneously Operational constraints: Discharging storage to provide one service (e.g. to defer T&D investment), limits its ability to provide other services brattle.com 6#7Approach Summary of Analytical Approach Analysis Inputs • • • bSTORE Identify Key Value Drivers Reduction in production costs Avoided generation capacity • T&D investment deferral Customer outage reduction Analytical Results Evaluate Additional Value Develop Simulation Inputs Nevada power system data • Simulate Storage With bSTORE Simulate 2020 and 2030 • Reduced emissions • Reduced renewable curtailment • WECC power system data • • Storage technical assumptions 200 MW and 1,000 MW storage at highest-value NV locations Provision of voltage support . Reduced T&D losses Quantify Ratepayer Benefits Compare customer costs with storage to Base Case without Develop Storage Cost Estimates Compare Ratepayer Benefits to Storage Cost Identify Cost-Effective Levels of Storage in 2020 and 2030 brattle.com 7#8Approach Data Sources We model Nevada consistent with NV Energy's 2018 IRP and rest of WECC consistent with 2026 TEPPC database (adjusting for 2020 and 2030). Data Element Transmission Topology NV and WECC Generator List Source(s) 2026 TEPPC Common Case (as updated in 2017 CAISO TPP) NV Energy's 2018 IRP, 2026 TEPPC Common Case, SNL NV and WECC Generator Characteristics NV Energy's 2018 IRP, 2026 TEPPC Common Case Fuel Prices NV and WECC Demand NV and WECC Reserve Requirements NV and WECC RPS Requirements T&D Deferral Analysis Distribution Reliability Analysis NV Energy's 2018 IRP, 2026 TEPPC Common Case, EIA NV Energy's 2018 IRP, 2026 TEPPC Common Case, SNL NV Energy's 2018 IRP, 2026 TEPPC Common Case NV Energy's 2018 IRP, Database of State Incentives for Renewables & Efficiency (DSIRE) NV Energy's Transmission and Distribution Capital Expenditure Data NV Energy's Distribution Outage Data brattle.com 8#9Approach Storage Technology Assumptions Although our analysis approach is technology agnostic, we simulate batteries with operational characteristics that resemble Li-Ion chemistry. - - Configuration and siting Stand-alone storage, not co-located with solar PV or other generator ⚫ Distribution and transmission connected • Sited in front-of-meter (behind-the-meter use case evaluated separately) -Size of individual storage devices: 5 to 10 MW MWh:MW ratio: 4:1 ⚫ Four hour discharge capability at full output • Consistent with types of storage systems procured in many recent solicitations Round-trip efficiency: 85% Lifespan: 15 years Notes: Assumptions developed with input from the PUCN and PNNL. Our fixed-cost and cost-levelization assumptions include the costs of replacing worn-out battery cells during the 15-year period. We do not assume degradation over time, consistent with the assumption that worn-out battery cells will be replaced throughout the 15-year period. brattle.com 9#10Approach Storage Installed Cost Trends We analyze a range of installed costs for 4-hour storage in 2020 and 2030 to reflect uncertainty we see in current cost projections. $3,000 Assumed Installed Costs for 10 MW, 40 MWh Storage Device Installed Cost ($/kW) $2,500 Lazard (2017) $2,000 NYSERDA (2018) $1,500 $1,000 $500 $0 Navigant (2017), High Hawaiian Electric (2016) DNV GL (2017) Lazard (2017) Brattle (High) NREL (2017) Navigant (2017), Base NIPSCO (2018), Median ESA (2016), Upper Navigant (2017), Low Brattle (Low) ESA (2016), Lower 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Sources and Notes: Literature review of Navigant (2017), Hawaiian Electric Companies (2016), NREL (2017), NIPSCO (2018), DNV GL (2017), NYSERDA (2018a), ESA (2016), and Lazard (2017). Installed cost estimates for a 4-hour storage system. All values in nominal dollars. brattle.com 10#11Note: Approach Levelization of Storage Costs We assume levelized installed costs of $136-204/kW-yr in 2020 and $99-149/kW-yr in 2030 for 4-hour storage device. Financial Assumptions Financial Assumption Fixed O&M Developer After-Tax WACC Battery Asset Life Balance of Plant Asset Life Total Income Tax Rate Depreciation Schedule Annual Inflation Rate Value % of Installed 1% % 7% yrs 15 yrs 15 % 21% 15-yr MACRS % 2% Levelized and Installed Cost Assumptions For 10 MW (40 MWh) Storage Device Implied Levelized Assumed Installed Costs $/kW Installed $/kWh Installed Costs $/kW-year Assumed Costs 2020 Low $1,200 $300 $136 2020 High $1,800 $450 $204 2030 Low $876 $219 $99 2030 High $1,314 $328 $149 Cost and financing assumptions indicative of new development costs in Nevada. All values in nominal dollars brattle.com | 11#12Approach Cost Effectiveness Framework We utilize the RIM test to evaluate cost-effectiveness of energy storage, including the value of avoided customer outages. The Ratepayer Impact Measure (RIM) test provides an indication of how average retail rates will change as the result of a new utility initiative - Includes all reductions in resource costs (e.g., reductions in fuel and capacity costs) Includes savings associated with procuring services more cheaply (e.g., ancillary services) We also include as a benefit the ratepayer value of avoided distribution outages - - Not traditionally included in RIM test (does not result a cost incurred by the utility), but reflects a benefit to ratepayers who experience fewer outages We separately report cost-effective storage levels excluding customer outage value We quantify, but do not include as ratepayer benefits, the societal cost impacts associated with changes in carbon and other emissions brattle.com 12#13Evaluation of Key Value Drivers brattle.com 13#14Evaluation of Key Value Drivers Reduction in Production Costs Approach - We use a production cost model - Power System Optimizer (PSO) – to estimate cost of meeting Nevada's energy and ancillary service needs. - We simulate entirety of WECC, with focus on Nevada - To account for changes in Nevada production costs, purchases, and sales, we calculated adjusted production costs (APC) for the Nevada footprint - We simulate 3 scenarios: base case (no storage), 200 MW, and 1,000 MW of storage Calculating Nevada Adjusted Production Costs (APC) Nevada Adjusted Production Costs = Production Costs + Cost of Purchases - Revenue from Sales WECC Footprint Production Costs = Cost of Nevada owned generation • Generation costs include fuel, emissions, variable operating, and startup costs Cost of Purchases = Deficit in generation × Price Hub • Purchases priced at the Malin and Mead hubs for Northern and Southern Nevada, respectively. Revenues from Sales = Surplus in generation * Price Hub • Sales priced at the Malin and Mead hubs for Northern and Southern Nevada, respectively. Cabos esri ©2018 S&P Global Market Intelligence All rights reserved. Esri, HERE, DeLorme, Mapmyndia, OpenStreetMap contributors Source: SNL brattle.com |14#15- - Evaluation of Key Value Drivers Reduction in Production Costs Findings We find APC savings of $4.5 to $16.5 million in 2020 (200 MW vs. 1,000 MW storage deployed), and $9.3 to $40.6 million in 2030. Savings due three factors: Reduced costs of operating NV generators Reduced imports during high priced hours Increased revenues from sales Savings account for the value of storage providing ancillary services Incremental savings (savings due to adding 1 additional MW of storage) fall as more storage is added and highest-value opportunities saturate 2020 Adjusted Production Cost Savings (in nominal $million/year) Savings (Storage Case minus Base Case) 1,000 MW Production Cost Base 200 MW 1,000 MW 200 MW Production Cost $421 $420 $423 ($1.1) $2.2 Cost of Market Purchases Revenues from Sales $132 $129 $124 ($3.1) ($7.9) ($46) ($46) ($57) ($0.4) ($10.8) $507 $502 $490 ($4.5) ($16.5) Total Estimated Incremental Benefit from APC Savings Incremental Benefit ($/kW-yr) Simulated $60 $50 Extrapolated from Simulation Results $40 2030 Incremental Benefit $30 2020 Incremental Benefit $20 $10 $0 200 400 600 800 1,000 Sources and Notes: Storage Deployed (MW) All values in nominal dollars. The total APC savings from simulations with 200 MW and 1,000 MW were used to estimate a relationship between storage deployed and total savings, from which we can estimate the relationship between storage deployed and incremental APC savings. brattle.com 15#16- - - Evaluation of Key Value Drivers Avoided Generation Capacity We find storage can effectively offset the need for additional peaking capacity in both 2020 and 2030, across all levels of deployment evaluated. If discharging during system peak load hours (net of renewable generation), storage offsets the need for other capacity Net peak load reductions valued at the market price for capacity assumed in 2018 NV Energy IRP We find 4-hour storage can effectively offset the need for new generation capacity Net load peaks concentrated in July and August Net load peaks are relatively short duration, due to high PV generation in summer months 2020 and 2030 Net Peak Reduction due to 200 MW and 1,000 MW of Storage MW % 200 MW 179 90% 1,000 MW 864 86% Nevada Net Load Peak Day Reduction (July 27, 2020) Load (MW) 9,000 8,000 7,000 6,000 5,000 200 MW Storage Addition 179 MW Peak Reduction 1,000 MW Storage Addition 864 MW Peak Reduction Nevada Net Load (before new storage) 1 MW of storage equivalent to 0.86 MW of capacity for simulated deployment of 1,000 MW 4,000 3,000 1 3 5 7 9 11 13 15 Hour of Day 17 19 21 23 brattle.com | 16#17Evaluation of Key Value Drivers Transmission & Distribution Investment Deferral Approach We used NV Energy capital expenditure data to identify high-value T&D deferral opportunities and evaluate how storage could defer investments. - NV Energy provided cost data and descriptions for 260 capital projects from 2014-2027 We estimate the subset that could be deferred by storage • We identified 35 projects (14% of total) are potentially deferrable by storage • Primarily transformer upgrades needed to support local load growth We estimate the value of deferring each investment by 15 years We make several assumptions to approximate how much storage may be require to defer an investment Initial Peak Load: based on NV Energy's project descriptions Rate of Load Growth: Assumed 2% Hourly Load Shape: Based on average residential or C&I load shapes - We size the storage to 15 year load growth * Average of NPC and SPPC After Tax Weighted Average Cost of Capital (ATWAAC) per NV Energy 2018 IRP, weighted by each system's contribution to total peak load. brattle.com 17#18Notes: Evaluation of Key Value Drivers Transmission & Distribution Investment Deferral Findings We identify a small number of high-value opportunities to defer specific T&D investments. Marginal T&D Deferral Benefit of Storage for Individual T&D Projects ($/kW-year) $140 $120 Marginal T&D Deferral Benefit ($/kW-year) $100 $80 $60 $40 $20 $0 0 100 200 300 400 500 600 700 800 Storage Installed (MW) Points reflect individual projects from NV Energy's 2018 transmission and distribution capital expenditure outlook identified as deferrable by storage. Although NV Energy's outlook is over a 10-year span, we annualize the size and value of opportunities. We order projects by $/kW-year value, and plot to estimate the marginal benefit for storage from T&D investment deferral. Values in nominal dollars. brattle.com 18#19Evaluation of Key Value Drivers Customer Outage Reduction Value Approach We evaluate the reliability value to customers of deploying storage on specific feeders that historical experience relatively high levels of outages. - NV Energy provided data on 43,000 distribution-level outages for 2014-2018 We evaluate customer outage reduction benefits of siting storage at least-reliable feeders • We simulate storage deployed at each identified feeder, sized at average feeder peak load Account for both the duration (hours) and magnitude (MWh) of each outage • Account for unpredictability of outages • Assume customers value improved reliability at $12,500/MWh value of lost load (VOLL) Analysis assumes feeders can be “islanded" in event of an outage Requires grid modernization investments, e.g. microgrids, automated distribution switching We separately report cost-effective storage levels if grid modernization efforts not made and customer outage value cannot be captured brattle.com 19#20Evaluation of Key Value Drivers Customer Outage Reduction Value Findings The marginal benefit from avoided distribution outages declines as storage is added to the least-reliable feeders. Marginal Reliability Benefit ($/kW-yr) $100 $90 Incremental Reliability Benefit of Storage ($/kW-year) Simulated Reliability Benefit (noisy because least reliable feeders that are allocated storage may or may not actually experience outages) $80 $70 $60 $50 Fitted Trendline $40 $30 $20 1 $10 $0 0 200 400 600 800 1,000 1,200 1,400 Storage Installed (MW) Note: All values in nominal dollars. brattle.com 20#21Aggregate System-Wide Benefits of Storage brattle.com 21#22Aggregate System-Wide Benefits Total System Benefits and Costs of Storage at Various Deployment Levels In 2020, storage benefits are less than costs if more than 200 MW deployed. In 2030, benefits exceed costs beyond 1,000 MW. $200 High Battery Cost 2020 $ million / year 2030 $ million/year $150 $100 $50 $0 200 400 600 800 1,000 Storage Deployment (MW) $200 $150 $100 $50 50 $0 200 400 600 800 1,000 Storage Deployment (MW) Note: All values are in nominal dollars Low Battery Cost Avoided Distribution Outages Deferred T&D Investment Production Cost Savings Avoided Capacity Investments Avoided Distribution Outages High Battery Cost Deferred T&D Investment Low Battery Cost Production Cost Savings Avoided Capacity Investments brattle.com 22#23Aggregate System-Wide Benefits Incremental Net Benefits of Storage Deployment in Nevada 2020 cost-effective storage levels are up to 175 MW, depending on storage costs. In 2030, cost-effective levels are greater than 700 MW. 2020 2030 Incremental Net Customer Benefit ($/kW-year) Incremental Net Customer Benefit ($/kW-year) $160 $120 $80 $40 $0 -$40 -$80 Net system benefits maximized at ~175 MW deployment. Low Battery Cost -$120 -$160 Storage not cost-effective at high end of current cost estimates. High Battery Cost 0 200 400 600 800 1,000 $160 Low Battery Cost $120 $80 $40 High Battery Cost $0 -$40 -$80 -$120 0 200 Storage Deployment (MW) 400 Net system benefits exceed costs for all deployment levels < 1000 MW. ↑ Net system benefits maximized at ~700 MW deployment. 600 Storage Deployment (MW) Incremental benefits of additional storage exceed costs Cost-effective storage level: Incremental benefits and costs of additional storage are equal Costs of adding additional storage exceed incremental benefits 800 1,000 brattle.com 23 Note: All values are in nominal dollars#24Aggregate System-Wide Benefits Renewable Integration and Emission Benefits Storage reduces WECC-wide emissions in both 2020 and 2030. Storage also reduces Nevada solar curtailments in 2030. Reduction in Nevada Renewable Generation Curtailments, 2030 Impact on WECC-Wide Emissions GWh [Change] - [Base] Base 200 MW 1,000 MW 200 MW 1,000 MW Change in Emissions (tons) Change in Emissions (%) 200 MW 1,000 MW 200 MW 1,000 MW Nevada Total Solar Generation 6,630 Solar Curtailment 57 6,633 54 6,659 28 3 29 2020 Cases -3 -29 CO2 -46,974 -131,998 -0.02% -0.06% Percent Change in Curtailment -5% -51% NOX 135 117 0.06% 0.05% S02 161 351 0.12% 0.26% 2030 Cases C02 NOX -63,162 -79 -234,955 -0.03% -0.10% -455 -0.03% -0.17% SO2 8 -480 0.00% -0.26% In 2020, minimal curtailments with or without storage - In 2030, 1,000 MW of storage significantly reduces curtailments - Storage reduces WECC-wide CO2 emissions in all cases Societal savings of $2.6 to $7.2 million in 2020 and $5.0 to $18.5 million in 2030* Emission reductions valued consistent with U.S. Government Interagency Working Group on the Social Cost of Carbon. Baseline 2020 value of $54/ton and 2030 value of $79/ton (3% discount rate scenario). See report for results under 5% and 2.5% discount rate scenarios. brattle.com 24#25Aggregate System-wide Benefits Sensitivities Storage is likely to be cost effective by 2030 across a variety of tested Sensitivity Base Case Zero Outage Reduction Value sensitivity cases. Storage outage reduction value not considered in RIM test or not realized due to lack of distribution upgrades Regional Market Cost-Effective Storage Level 2020 2030 Up to 175 MW >700 MW 0 MW >300 MW Implementation of regional market reduces regional production costs, halving storage production cost savings n/a >400 MW Zero Avoided Generation Capacity Value No need for additional generation capacity, e.g. declining load growth and no open capacity position n/a Up to 300 MW brattle.com 25#26Behind-the-Meter Storage Applications brattle.com 26#27BTM Applications Overview We evaluate the economic potential for BTM storage adoption by C&I customers with and without a utility-administered program. C&I customers most likely to adopt BTM storage in the near- to medium-term - Uses include retail bill reduction, backup generation, and aggregation as DR Significant residential adoption unlikely, absent changes to retail rate design and NEM policy The utility could incentivize further adoption of BTM storage Incentive could take the form of a cost-effective payment - In return, utility would control device for a limited number of days per year to address resource adequacy needs brattle.com 27#28BTM Applications Approach to Quantifying BTM Storage Potential We use a 7-step process to evaluate BTM adoption with and without a utility-administered program 3 Identify applicable retail rate design Establish customer load patterns Simulate storage dispatch using Define BTM storage operational characteristics bSTORE Bill savings 5 Calculate payback period BTM storage costs Customer investment payback period Quantify long- run BTM storage adoption Impact of utility BTM storage incentive program brattle.com 28#29BTM Applications Projected Cumulative BTM Storage Adoption with and without Utility Incentive Programs A utility BTM storage program could increase adoption by up to 20 MW in 2020 and 39 MW in 2030. 80 70 26 Megawatts WA 60 50 40 Notes: 2020 30 20 20 20 10 1 6 0 Low Case Medium Case High Case 6 Low Case 2030 18 Medium Case The potential estimates represent long-run adoption potential based on assumed storage costs for the years shown in the figure. It would take several years to reach these adoption levels. Incremental impact of incentive 39 payment Adoption without incentive High Case brattle.com 29#30Comparison to Other Storage Potential Studies brattle.com 30#31Storage MW as % of System Peak 14% 12% 10% Comparison to Other Studies Comparison of Cost-Effective Storage Deployment Levels Across Studies We find lower cost-effective storage levels than other studies in 2020 (proportional to system peak). 2030 findings similar to NY study. Massachusetts New York ■(Peaker Retirement case) New York ■(Peaker Retirement case) ■Nevada (Low Cost Case) ■New York (Base Case) Nevada (High Cost Case) 8% ■Texas (Brattle) 6% ■New York (Base Case) ■Texas (Navigant) 4% 2% ■Nevada (Low Cost Case) 0% 2018 2020 ■Nevada (High Cost Case) 2022 2024 2026 2028 2030 brattle.com 31#32Study Conclusions brattle.com 32#33Study Conclusions Conclusions Energy storage deployments can be cost-effectively incorporated into Nevada's future power supply mix. - Energy storage can provide value across several applications. This finding is robust across a range of modeled scenarios - In 2020, up to 175 MW could be cost-effective if storage at lower end of projected cost range By 2030, cost-effective levels exceed 700 MW Utility BTM incentive programs could increase adoption by up to 20 MW in 2020 and up to 39 MW in 2030 Additional feasibility studies would be valuable to further validate these conclusions brattle.com 33#34Storage Installed Cost ($/kW) Study Conclusions Optimal Storage Deployment Curves Future procurements could be expressed as an "optimal deployment curve" to account for cost uncertainty and changing system conditions. $2,000 $1,800 $2,000 $1,800 $1,600 $1,400 Energy storage not cost-effective at the upper-bound of the forecasted 2020 storage cost range ($1,800/kW) Range of $1,600 costs considered $1,400 $1,200 $1,000 $800 $1,200 2020 $1,000 $800 $600 $600 $400 $200 ② At the lower bound of the 2020 storage cost range ($1,200/kW), the optimal storage deployment level is 175 MW $400 ① At the upper-bound of the 2030 storage cost range ($1,310/kW), optimal deployment is around 700 MW ②At the lower-bound of the 2030 storage cost range ($880/kW), optimal storage deployment reaches the total system- wide need for new capacity (1,000 MW) $200 $0 $0 0 200 400 600 800 1,000 0 200 400 600 Notes: Estimated Optimal Storage Deployment (MW) 2030 Range of costs considered 800 1,000 Estimated Optimal Storage Deployment (MW) Costs are shown in nominal dollars. Values are based on an assumed energy storage configuration of 10 MW / 40 MWh. brattle.com 34#35Author Contact Information RYAN HLEDIK Principal |New York, NY [email protected] 415.789.3684 ROGER LUEKEN Associate Washington, DC [email protected] +1.202.419.3321 JUDY CHANG Principal and Director | Boston, MA [email protected] +1.617.234.5630 JOHANNES PFEIFENBERGER Principal Boston, MA [email protected] +1.617.234.5624 The views expressed in this presentation are strictly those of the presenter(s) and do not necessarily state or reflect the views of The Brattle Group, Inc. or its clients. brattle.com 35#36Additional Reading "Maximizing the Market Value of Flexible Hydro Generation," Pablo Ruiz, James A. Read, Jr., Johannes Pfeifenberger, Roger Lueken, and Judy Chang, Comments in Response to DOE's Request for Information DE-FOA-0001886, April 4, 2018 "Getting to 50 GW? The Role of FERC Order 841, RTOs, States, and Utilities in Unlocking Storage's Potential," Roger Lueken, Judy Chang, Johannes P. Pfeifenberger, Pablo Ruiz, and Heidi Bishop, Presented at Infocast Storage Week, February 22, 2018 "Battery Storage Development: Regulatory and Market Environments," Michael Hagerty and Judy Chang, Presented to the Philadelphia Area Municipal Analyst Society, January 18, 2018 "U.S. Federal and State Regulations: Opportunities and Challenges for Electricity Storage," Romkaew Broehm, Presented at BIT Congress, Inc.'s 7th World Congress of Smart Energy, November 2, 2017 "Stacked Benefits: Comprehensively Valuing Battery Storage in California," Ryan Hledik, Roger Lueken, Colin McIntyre, and Heidi Bishop, Prepared for Eos Energy Storage, September 12, 2017 "The Hidden Battery: Opportunities in Electric Water Heating," Ryan Hledik, Judy Chang, and Roger Lueken, Prepared for the National Rural Electric Cooperative Association (NRECA), the Natural Resources Defense Council (NRDC), and the Peak Load Management Alliance (PLMA), February 10, 2016 "Impacts of Distributed Storage on Electricity Markets, Utility Operations, and Customers," Johannes Pfeifenberger, Judy Chang, Kathleen Spees, and Matthew Davis, Presented at the 2015 MIT Energy Initiative Associate Member Symposium, May 1, 2015 "The Value of Distributed Electricity Storage in Texas - Proposed Policy for Enabling Grid-Integrated Storage Investments," loanna Karkatsouli, James Mashal, Lauren Regan, Judy Chang, Matthew Davis, Johannes Pfeifenberger, and Kathleen Spees, Prepared for Oncor, March 2015 brattle.com 36#37About The Brattle Group The Brattle Group provides consulting and expert testimony in economics, finance, and regulation to corporations, law firms, and governmental agencies worldwide. We combine in-depth industry experience and rigorous analyses to help clients answer complex economic and financial questions in litigation and regulation, develop strategies for changing markets, and make critical business decisions. Our services to the electric power industry include: ■Climate Change Policy and Planning ■ Cost of Capital ■Demand Forecasting Methodology ■Demand Response and Energy Efficiency Electricity Market Modeling Energy Asset Valuation Energy Contract Litigation ■ Environmental Compliance Fuel and Power Procurement Incentive Regulation ■Rate Design and Cost Allocation Regulatory Strategy and Litigation Support Renewables ■Resource Planning ■Retail Access and Restructuring ■Risk Management Market-Based Rates ■Market Design and Competitive Analysis Mergers and Acquisitions Transmission brattle.com | 37#38Our Practices and Industries ENERGY & UTILITIES Competition & Market Manipulation Distributed Energy Resources Electric Transmission Electricity Market Modeling & Resource Planning Electrification & Growth Opportunities Energy Litigation Energy Storage Environmental Policy, Planning and Compliance Finance and Ratemaking Gas/Electric Coordination Market Design Natural Gas & Petroleum Nuclear Renewable & Alternative Energy LITIGATION Accounting Analysis of Market Manipulation Antitrust/Competition Bankruptcy & Restructuring Big Data & Document Analytics Commercial Damages Environmental Litigation & Regulation Intellectual Property International Arbitration International Trade Labor & Employment Mergers & Acquisitions Litigation Product Liability Securities & Finance Tax Controversy & Transfer Pricing Valuation White Collar Investigations & Litigation INDUSTRIES Electric Power Financial Institutions Infrastructure Natural Gas & Petroleum Pharmaceuticals & Medical Devices Telecommunications, Internet, and Media Transportation Water brattle.com 38#39Our Offices BOSTON NEW YORK SAN FRANCISCO WASHINGTON TORONTO LONDON MADRID ROME SYDNEY brattle.com 39#40THE POWER OF ECONOMICS brattle.com THE Brattle GROUP

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