Thursday, January 3, 2013

Response to the Union of Concerned Scientists' "Critique" of BHI's RPS studies

Elliott Negin,
Director of News & Commentary
Union of Concerned Scientists
Huffington Post

Dear Mr. Negin:

I write this letter to you to correct your statements and misrepresentation of our studies that you presented to your readers in an article titled Koch Brothers Fund Bogus Studies to Kill Renewable Energy on December 7th 2012.

You state that I ‘essentially conceded’ that we ‘fudged’ our findings due to the funding of groups that utilized our findings or assumptions you make about our funding. This could not be further from the truth, and as I will detail here, your deceptive selections of our papers and incorrect statements are misleading your readers.

As with all of our Renewable Portfolio Standard (RPS) reports the donors and funders of the project wish to remain anonymous, but as I will demonstrate, none of our numbers are ‘fudged.’ We use rigorous analysis and a dynamic economic model with an 11-year track record to produce accurate ranges for the estimated costs that states are likely to experience due to RPS polices. The fact is that by mandating that utilities produce electricity by using more costly and less efficient methods, electricity costs will rise. These price increases are not immaterial and will have direct effect on decisions faced by both residents and businesses in the state.

I do not question the findings or independence of the Union of Concerned Scientists, or yourself, due to the eight Anonymous donations of more than $100,000, or donations from ClimateWorks Foundation, EarthShare or The Energy Foundation of the same size. (1) To do so would be to commit the motive fallacy which always seems to be used by those with no legs to stand on. Questioning funding sources is the ‘red herring’ to avoid any serious discussion on methodical issues in a study. But I do question your findings based on incorrect information and misleading statements.

First, you quote our paper:

“assumed that the Energy Information Administration’s projected renewable energy price estimates are too low,”

Which is true, but you leave out the part of the story that does not fit your caricature of findings that disagree with your belief. In our research we found that EIA estimates were in the lower range of levelized energy costs and higher in capacity factor for renewable energies for the nation as a whole. For this reason we included them in our paper, as the ‘low case’ to fully represent the huge range of possibilities that this policy could have. We also included other creditable estimates in our modeling to represent a ‘high case’, as well as a combination of the two sets to calculate our ‘medium case’. Additionally, in our calculations we use state specific information when it is available. For example actual wind power farms in Kansas have capacity factors close to 40 percent, higher than EIA estimates, which we utilized to improve our results.

Secondly, to continue the quote above:

“…and that cost containment measures embedded in state polices will fail.”

But again you fail to include any of our discussion of why they are likely to fail, and regardless should not be included in an examination of the policies. In researching the cost caps, we were unable to find any examples of effective, enforceable cost caps for RPS or Renewable Energy Standards (RES) being enforced. This is not particularly surprising, as most policies have step-up mechanisms and the larger costs are likely to be incurred as the policies are fully implemented. But it does begin to show a trend. Furthermore, most cost containment measures are worded such that the decision to implement them is more likely to be a political decision then an economic one.

For example, in Missouri the Missouri Public Service Commission (MPSC), which is the department responsible for measuring the cost cap, as well as ensuring the RPS is fully implemented, should determine the rate increase “by estimating and comparing the electric utility’s cost of compliance with least-cost renewable generation and the cost of continuing to generate or purchase from entirely nonrenewable sources.” Additionally, “future environmental regulatory risk including that of greenhouse gas regulations should be taken into account.”(2) If a MPSC analyst can determine the least cost energy of a theoretical power plant, the cost of a theoretical purchase contract, AND determine the cost of all possible future environmental regulations, then the analyst would be wasting his skills.

Aside from the points mentioned above about the cost-cap provisions, they are irrelevant to the goal of our study, which is to estimate the cost of compliance to a RPS in the time frame legislated. There are three possible outcomes of the RPS. It is (1) met in the timeframe required, (2) the cost cap provision is enacted and the RPS is not met in the timeframe required or (3) the RPS is not met due to technical impossibilities. Our studies measure (1) as (2) is more based on political science, requiring large assumptions, than economics while (3) is not relevant to policy discussion.

Thirdly, you reference your colleague’s ‘fact check’ of our Michigan RPS analysis. This ‘fact check’ plays fast and loose with the facts, making false claims and entirely misrepresenting our study. I will supply the summary corrections again for you here.

You said we “ignored the fact that the state already has a standard in place, enabling them to inflate the costs of implementing the stronger standard.” This would be a valid critique, if it were true. In fact, in Graphic 2 of the paper we compare the two polices side by side, including the results of the difference between the two policies.

Next you stated that we “made questionable assumptions about renewable energy technologies--often citing out-of-date, controversial or unsubstantiated material to support their assertions--instead of using real-world cost and performance data from local projects.” As stated above, we use a range of estimate to provide a better interval that we are confident the results will be in. In Mr. Deyette’s ‘fact-check’, he suggests we use capacity factors for wind power based on the Great Lakes region. The number he suggests is within our range of estimates, which is one of the most defensible reasons for using ranges. No one knows what the capacity factor of wind will be in 2025, we make assumptions about the range to provide a range of net costs as guidance.

Finally, you allege we “failed to factor in the new standard's benefits, including economic development, job growth, cleaner air and reduced carbon pollution.” We go to lengths in both the papers and the STAMP® documentation to show this is not true, and your statement is uninformed. As we state in the paper:

“The jobs that are lost due to higher energy costs are not as easy to identify as the jobs created by new energy construction projects, but they are just as important. While Public Act 295 might generate visible new jobs and construction projects, our projections clearly indicate that Michigan electricity ratepayers will pay higher rates, face fewer employment opportunities, and see investment redirected to other states.”

The STAMP® model does account for the benefits of the policy. More jobs and investment will be seen in some sectors of the Michigan economy, mainly in those related to the installation and building of green energy. But the higher electric prices would have larger negative effects on the state, leading to the net negative costs we report.

Your haphazard analysis which makes-up facts and consistently misconstrues statements is an insult to your readers and a sad inquiry into our paper. I would be happy to discuss any methodical questions or concerns you have with our papers in an effort to improve them, but accusing me of ‘fudging’ studies for money based on ignorant facts is disappointing.


Michael Head
Research Economist
The Beacon Hill Institute at Suffolk University

cc: Joanna Zelman, Editor, Green Department, Huffington Post.
1 Union of Concerned Scientists, Annual Report (2011);14,
2 Missouri Register 35 (16):1190 August 16, 2010.

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