Monthly Archives: August 2024

How to properly calculate the marginal GHG emissions from electric vehicles and electrification

Recently the questions about whether electric vehicles increase greenhouse gas (GHG) emissions and tracking emissions directly to generation on a 24/7 basis have gained saliency. This focus on immediate grid-created emissions illustrates an important concept that is overlooked when looking at marginal emissions from electricity. The decision to consume electricity is more often created by a single large purchase or action, such as buying a refrigerator or a new electric vehicle, than by small decisions such as opening the refrigerator door or driving to the grocery store. Yet, the conventional analysis of marginal electricity costs and emissions assumes that we can arrive at a full accounting of those costs and emissions by summing up the momentary changes in electricity generation measured at the bulk power markets created by opening that door or driving to the store.

But that’s obviously misleading. The real consumption decision that created the marginal costs and emissions is when that item is purchased and connected to the grid. And on the other side, the comparative marginal decision is the addition of a new resource such as a power plant or an energy efficiency investment to serve that new increment of load.

So in that way, your flight to Boston is not whether you actually get on the plane, which is like opening the refrigerator door, but rather your purchase of the ticket which led to the incremental decision by the airline to add another scheduled flight. It’s the share of the fuel use for that added flight which is marginal, just as buying a refrigerator is responsible for the share of the energy from the generator added to serve the incremental long-term load.

There are growing questions about the use of short run market prices as indicators of market value of generation assets for a number of reasons. This paper critiquing “surge” pricing on the grid has one set of aspects that undermine that principle.

Meredith Fowley at the Energy Institute at Haas compared two approaches to measuring the additional GHG emissions from a new electric vehicle. The NREL paper uses the correct approach of looking at longer term incremental resource additions rather than short run operating emissions. The hourly marginal energy use modeled by Holland et al (2022) is not particularly relevant to the question of GHG emissions from added load for several reasons and for that reason any study that doesn’t use a capacity expansion model will deliver erroneous results. In fact, you will get more accurate results from relying on a simple spreadsheet model using capacity expansion than a complex production cost hourly model.

In the electricity grid, added load generally doesn’t just require increased generation from existing plants, but rather it induces investment in new generation (or energy savings elsewhere, which have zero emissions) to meet capacity demands. This is where economists make a mistake thinking that the “marginal” unit is additional generation from existing plants–in a capacity limited system such as the electricity grid, its investment in new capacity.

That average emissions are falling as shown in Holland et al while hourly “marginal” emissions are rising illustrates this error in construction. Mathematically that cannot be happening if the marginal emission metric is correct. The problem is that Holland et al have misinterpreted the value they have calculated. It is in fact not the first derivative of the average emission function, but rather the second partial derivative. That measures the change in marginal emissions, not marginal emissions themselves. (And this is why long-run marginal costs are the relevant costing and pricing metric for electricity, not hourly prices.) Given that 75% of new generation assets in the U.S. were renewables, it’s difficult to see how “marginal” emissions are rising when the majority of new generation is GHG-free.

The second issue is that the “marginal” generation cannot be identified in ceteris paribus (i.e., all else held constant) isolation from all other policy choices. California has a high RPS and 100% clean generation target in the context of beneficial electrification of buildings and transportation. Without the latter, the former wouldn’t be pushed to those levels. The same thing is happening at the federal level. This means that the marginal emissions from building decarbonization and EVs are even lower than for more conventional emission changes.

Further, those consumers who choose beneficial electrification are much more likely to install distributed energy resources that are 100% emission free. Several studies show that 40% of EV owners install rooftop solar as well, far in excess of the state average, (In Australia its 60% of EV owners.) and they most likely install sufficient capacity to meet the full charging load of their EVs. So the system marginal emissions apply only to 60% of EV owners.

There may be a transition from hourly (or operational) to capacity expansion (or building) marginal or incremental emissions, but the transition should be fairly short so long as the system is operating near its reserve margin. (What to do about overbuilt systems is a different conversation.)

There’s deeper problem with the Holland et al papers. The chart that Fowlie pulls from the article showing that marginal emissions are rising above average emissions while average emissions are falling is not mathematically possible. (See for example, https://www.thoughtco.com/relationship-between-average-and-marginal-cost-1147863) For average emissions to be falling, marginal emissions must be falling and below average emissions. The hourly emissions are not “marginal” but more likely are the first derivative of the marginal emissions (i.e., the marginal emissions are falling at a decreasing rate.) If this relationship holds true for emissions, that also means that the same relationship holds for hourly market prices based on power plant hourly costs.

All of that said, it is important to incentivize charging during high renewable hours, but so long as we are adding renewables in a manner that quantitatively matches the added EV load, regardless of timing, we will still see falling average GHG emissions.

It is mathematically impossible for average emissions to fall while marginal emissions are rising if the marginal emission values are ABOVE the average emissions, as is the case in the Holland et al study. What analysts have heuristically called “marginal” emissions, i.e., hourly incremental fuel changes, are in fact, not “marginal”, but rather the first derivative of the marginal emissions. And as you point out the marginal change includes the addition of renewables as well as the change in conventional generation output. Marginal must include the entire mix of incremental resources. How marginal is measured, whether via change in output or over time doesn’t matter. The bottom line is that the term “marginal” must be used in a rigorous economic context, not in a casual manner as has become common.

Often the marginal costs do not fit the theoretical mathematical construct based on the first derivative in a calculus equation that economists point to. In many cases it is a very large discreet increment, and each consumer must be assigned a share of that large increment in a marginal cost analysis. The single most important fact is that for average costs to be rising, marginal costs must be above average costs. Right now in California, average costs for electricity are rising (rapidly) so marginal costs must be above those average costs. The only possible way of getting to those marginal costs is by going beyond just the hourly CAISO price to the incremental capital additions that consumption choices induce. It’s a crazy idea to claim that the first 99 consumers have a tiny marginal cost and then the 100th is assigned the responsibility for an entire new addition such as another flight scheduled or a new distribution upgrade.

We can consider the analogy to unit commitment, and even further to the continuous operation of nuclear power plants. The airline scheduled that flight in part based on the purchase of the plane ticket, not on the final decision just before the gate was closed. Not flying saved a miniscule amount of fuel, but the initial scheduling decision created the bulk of the fuel use for the flight. In a similar manner a power plant that is committed several days before an expected peak load burns fuels while idling in anticipation of that load. If that load doesn’t arrive, that plant avoids a small amount of fuel use, but focusing only on the hourly price or marginal fuel use ignores the fuel burned at a significant cost up to that point. Similarly, Diablo Canyon is run at a constant load year-round, yet there are significant periods–weeks and even months–where Diablo Canyon’s full operational costs are above the CAISO market clearing price average. The nuclear plant is run at full load constantly because it’s dispatch decision was made at the moment of interconnection, not each hour, or even each week or month, which would make economic sense. Renewables have a similar characteristic where they are “scheduled and dispatched” effectively at the time of interconnection. That’s when the marginal cost is incurred, not as “zero-cost” resources each hour.

Focusing solely on the small increment of fuel used as a true measure of “marginal” reflects a larger problem that is distorting economic analysis. No one looks at the marginal cost of petroleum production as the energy cost of pumping one more barrel from an existing well. It’s viewed as the cost of sinking another well in a high cost region, e.g., Kern County or the North Sea. The same needs to be true of air travel and of electricity generation. Adding one more unit isn’t just another inframarginal energy cost–it’s an implied aggregation of many incremental decisions that lead to addition of another unit of capacity. Too often economics is caught up in belief that its like classical physics and the rules of calculus prevail.

A Residential Energy Retrofit Greenhouse Gas Emission Offset Reverse Auction Program

In most local California jurisdictions, the largest share of stationary emissions will continue to come from the existing buildings. On the other hand, achieving zero net energy (ZNE) or zero net carbon (ZNC) for new developments can be cost prohibitive, particularly if incremental transportation emissions are included. A Residential Retrofit Offset Reverse Auction Program (Retrofit Program) aims to balance emission reductions from both new and existing buildings s to lower overall costs, encourage new construction that is more energy efficient, and incentivize a broader energy efficiency marketplace for retrofitting existing buildings.

The program would collect carbon offset mitigation fees from project developers who are unable to achieve a ZNE or ZNC standard with available technologies and measures. The County would then identify eligible low-income residential buildings to be targeted for energy efficiency and electrification retrofits. Contractors then would be invited to bid on how many buildings they could do for a set amount of money.

The approach proposed here is modeled on the Audubon Society’s and The Nature Conservacy’s BirdReturns Program.[1] That program contracts with rice growers in the Sacramento Valley to provide wetlands in the Pacific Flyway. It asks growers to offer a specified amount of acreage with given characteristics for a set price–that’s the “reverse” part of the auction.

A key impediment to further adoption of energy efficiency measures and appliances is that contractors do not have a strong incentive to “upsell” these measures and products to consumers. In general, contractors pass through most of the hardware costs with little markup; their profits are made on the installation and service labor. In addition, contractors are often asked by homeowners and landlords to provide the “cheapest” alternative measured in initial purchase costs without regard to energy savings or long-term expenditures.

The Retrofit Program is intended to change the decision point for contractors to encourage homeowners and landlords to implement upgrades that would create homes and buildings that are more energy efficient. Contractors would bid to install a certain number of measures and appliances that exceed State and local efficiency standards in exchange for payments from the Retrofit Program. The amount of GHG reductions associated with each type of measure and appliance would be predetermined based on a range of building types (e.g., single-family residential by floor-size category, number of floors, and year built). The contractors can use the funds to either provide incentives to consumers or retain those funds for their own internal use, including increased profits. Contractors may choose to provide more information to consumers on the benefits of improved energy efficiency as a means of increasing sales. Contractors would then be compensated from the Offset Program fund upon showing proof that the measures and appliances were installed. The jurisdiction’s building department would confirm the installation of these measures in the normal course of its permit review work.

Funds for the Retrofit Program would be collected as part of an ordinance for new building standards to achieve the no-net increase in GHG emissions. It also could be included as a mitigation measure for projects falling under the purview of the California Environmental Quality Act (CEQA.)

The Retrofit Program would be financed by mitigation payments made by building developers to achieve a no-net increase in GHG emissions. Buildings would be required to meet the lowest achievable GHG emission levels, but then would pay to mitigate any remainders, including for transportation, charged at the current State Cap and Trade Program auction price for an extended collection of annual allowances[2] that cover emissions for the expected life of the building (e.g., 40 years) (CARB 2024).

M.Cubed proposed this financing mechanism for Sonoma County in its climate action plan.


[1] See https://birdreturns.org/

[2] Referred to as a “strip” in the finance industry.

A Working Lands Carbon Mitigation Bank Program

A number of counties in California are largely agricultural, with a few small communities. Most of that agricultural land is intensively farmed, much of it irrigated. This situation presents the opportunity to sequester large amounts of carbon relative to the total greenhouse gas emissions from all county activities. In other words, the county can approach a level of net-zero emissions with a surplus available to share with other jurisdictions, particularly with those in within a county.

Since many of these counties are already planning to use this sequestration strategy to meet its own emission reduction goals, these reductions will be real, additional, and verifiable, meeting the gold standard for use as credits by other jurisdictions. The county has a strong incentive to ensure that these reductions are of sufficient quality to meet its own targets, which should make these attractive to other jurisdictions, unlike other credits offered in the marketplace.

A county would establish a Carbon Mitigation Bank using a similar framework to habitat conservation mitigation banks.[1] The county would establish the parameters that achieve the requisite carbon sequestration and then collect in-lieu fees to cover the costs of the bank’s expenses. By expanding the number of jurisdictions contributing and receiving coverage, overall carbon emissions can be reduced more cost-effectively.

Sequestration from working lands can be achieved at a lower cost than most alternatives. For this reason, a county can use its surplus to finance much of its share of the sequestration program by offering it to cities in the county at a margin above the implementation cost sufficient to cover the county’s share of the costs as well. For example, it may cost $50 per CO2e ton sequestered, and the County may use only half of the potential sequestration to meet its own target. The County could then offer its surplus credits to the other jurisdictions at $100 per ton, which is likely less than the cost of additional reductions elsewhere, to cover the full program costs.

M.Cubed proposed this financing mechanism for both Yolo and Sonoma in their climate action plans. Both counties could potentially sequesters hundreds of thousands of tons annually, implying this could be a major revenue source for meeting broader targets.