Consumer Perspectives 

on Carbon Markets

Office of the People’s Counsel for the District of Columbia

CFTC Energy and Environmental Markets Advisory Committee

June 3, 2021
Overview of DC OPC

• By law, DC OPC is the statutory advocate for consumers of 

regulated utility service in the District of Columbia.

• DISCLAIMER- Presentation is for discussion purposes only and 

does not reflect the policies or positions the Office or the People’s 

Counsel may take on any specific matter.
No Longer Just “Least Cost”

• From “reliability at least cost” to “cost effective reliability and 

sustainability”

• Consumer advocate offices, like DC OPC, are charged with helping 

meet sustainability goals in an affordable manner

• Concerns regarding environmental justice and cost impacts of 

clean energy goals on low- and moderate-income ratepayers

• Need robust solutions that balance multiple considerations 

including cost, reliability/resiliency, environment, and economy
Growing Importance of 

Sustainability

Washington, DC

• The District has robust de-carbonization goals, including reducing 

carbon emissions 50% by 2032 and carbon neutrality by 2050

National Picture

• More then half the states have established renewable energy 

targets

• 30 states, Washington, D.C., and three territories have adopted 

Renewable Portfolio Standards (RPS)

• 14 states, Washington, D.C., Puerto Rico, and the Virgin Islands 

have RPS requirements of 50% or greater
Overview of Current 

Sustainability Targets

• Very diverse—some states with robust targets, others with little 

or none

• Different definitions of “renewable resources”

• Difficult for multistate organized markets (PJM, MISO, etc.) to 

develop carbon pricing—questions regarding border adjustments

• Some cooperation across borders/markets—Regional 

Greenhouse Gas Initiative (RGGI) 
2005 – 2020 PJM Average Emissions

0.0

www.pjm.com | Public 6 PJM©2021

1.5

3.0

4.5

6.0

7.5

9.0

700

800

900

1,000

1,100

1,200

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

SO2 and NOx

(lbs/MWh)

CO2

(lbs/MWh)

1,300

Carbon Dioxide 

Sulfur Dioxide 

Nitrogen Oxides
Significant Reductions in 

Carbon Already Achieved

• PJM region has seen significant reductions in carbon over the last 

15 years, largely due to the transition from coal to natural gasbased generation

• Has the “low hanging fruit” been harvested?

• What role can carbon pricing play in helping achieve deep 

decarbonization?
Potential Benefits of 

Carbon Pricing

• Create uniform value for all resources, carbon-free and thermal

• Pricing across a region may address some border adjustment 

issues

• Reduce the need for individual state policies to encourage low 

carbon resources

• Address perceived concerns regarding state policies and 

organized markets
Questions Regarding 

Carbon Pricing

• Demonstrable cost/benefit to consumers—higher costs must 

come with clear benefits to sustainability

• Equitable and just distribution of revenue from carbon pricing

• Appropriate scope—sub-market, RTO, multi-market, nation 

wide

• Matching incentives with goals

• Forward-looking nature of the market
Role of the CFTC

• Recognition of the use of carbon pricing as a hedging tool

• Ensure transparency and market liquidity

• Ensure consumers are protected from market manipulation or 

failure
Questions?

Contact Information

Erik Heinle, fheinle@opc-dc.gov