Client: Green Energy Consumers Alliance (GECA)
Authors: Liz Stanton, PhD, and Ricardo Lopez, PhD
Applied Economics Clinic (AEC) replicated the calculations described in National Grid’s proposed off-peak charging rebate. AEC’s estimates of summer and winter off-peak charging rebates — using the methodology and data described in detail by National Grid — resulted in values similar but not identical to those presented by the Company. AEC concludes that the rebate levels proposed by National Grid represent a reflection of the reduced cost of service for off-peak charging and not a cross-subsidy. In addition, this comment raises several categories of potential additional peak to off-peak cost differentials and sources of charging revenue omitted in National Grid’s charging rebate methodology, including avoided transmission and distribution costs, avoided emissions costs, and funding for energy efficiency programs.