

The following are comments prepared By Geoffrey Young on behalf of the Sierra Club Cumberland Chapter concerning Administrative Case No. 2006-00045 on electric utility interconnection standards and time-of-use rates. These comments were issued to the Kentucky Public Service Commission on July 18, 2006 at a public hearing on this case.
BEFORE THE PUBLIC SERVICE COMMISSION
In the Matter of:
CONSIDERATION OF THE )
REQUIREMENTS OF THE FEDERAL )
ENERGY POLICY ACT OF 2005 ) CASE NO.
REGARDING TIME-BASED METERING, ) 2006-00045
DEMAND RESPONSE AND )
INTERCONNECTION SERVICE )
COMMENTS OF THE
The following comments were drafted primarily by Geoffrey
Young and were approved by the Energy Committee of the Cumberland Chapter
(which is the
I. Introduction
On February 24, 2006, the Kentucky Public Service Commission (PSC) initiated this administrative proceeding to consider the requirements of the Energy Policy Act of 2005 (EPAct 2005), Subtitle E, Sections 1252 on smart metering and 1254 on interconnection. The Cumberland Chapter of the Sierra Club elected not to request intervention in the case, but is submitting its comments pursuant to the procedural schedule set forth in Appendix D of the PSC’s Order of 2/24/06.
The Sierra Club is primarily concerned with policies that
improve energy efficiency in all sectors of the
II. Interconnection
The standard proposed by Section 1254 is as follows: “Each electric utility shall make available, upon request, interconnection service to any electric consumer that the electric utility serves. For purposes of this paragraph, the term ‘interconnection service’ means service to an electric consumer under which an on-site generating facility on the consumer’s premises shall be connected to the local distribution facilities.” The standard incorporates IEEE Standard 1547 and calls for the use of “current best practices of interconnection for distributed generation.” Finally, the standard states that “All such agreements and procedures shall be just and reasonable, and not unduly discriminatory or preferential.”
The first question the PSC has raised is whether
In May 2000, the National Renewable Energy Laboratory published a report titled, “Making Connections: Case Studies of Interconnection Barriers and their Impact on Distributed Power Projects.” (R. Brent Alderfer, M. Monika Eldridge, and Thomas J. Starrs; NREL Technical Monitor was Gary Nakarado; publication number NREL/SR-200-28053. It is available online at http://www.nrel.gov/docs/fy00osti/28053.pdf) Of 65 case studies for which sufficient information existed to include in the report, 58 projects encountered utility-related barriers. Sometimes the barriers were so severe as to prevent the project from being implemented. Proponents of potential DG systems reported numerous artificial barriers including the following:
The report provided a ten-point action plan for reducing barriers to DG. The first point was: “(1) Adopt uniform technical standards for interconnecting distributed generation to the grid.”
The Executive Summary concludes with the following two
paragraphs, which are directly relevant to the situation in
“Much more must be done in order to create a regulatory, policy, and business environment which does not create artificial market barriers to distributed generation. The barriers distributed generation projects face today go beyond the problems of technical interconnection standards or process delay, which are more immediately apparent to the market. They grow out of long-standing regulatory policies and incentives designed to support monopoly supply and average system costs for all ratepayers. In the present regulatory environment, utilities have little or no incentive to encourage distributed power. To the contrary, regulatory incentives drive the distribution utility to defend the monopoly against market entry by distributed power technologies. Revenues based on throughput and system average pricing are optimized by keeping maximum loads and highest revenue customers on the system. But, as in any competitive market, those are the customers that gain the most by switching to new, more economic, efficient, or customized power alternatives. In addition, current tariffs and rate design as a rule do not price distribution services to account for system benefits that could be provided by distributed generation.
“Resolution on a state-by-state basis will not address what may be the biggest barrier for distributed generation – a patchwork of rules and regulations which defeat the economies of mass production that are natural to these small modular technologies. Although regulatory proceedings and legal challenges eventually would resolve most of the identified barriers, national collaborative efforts among all stakeholders are necessary to accelerate this process so that near-term emerging markets for the new distributed generation technologies are not stymied. Distributed generation promises greater customer choice, efficiency advantages, improved reliability, and environmental benefits. Removing artificial barriers to interconnection is a critical step toward allowing distributed generation to fulfill this promise.”
The passage of Section 1254 of EPACT 2005 can be thought of
as a kind of “national collaborative effort among stakeholders” as suggested
above, or at least as an impetus for various parties to work together. Although the adoption of the standard
specified in Section 1254 by
The final element of the proposed interconnection standard – that all interconnection “agreements and procedures shall be just and reasonable, and not unduly discriminatory or preferential” – is far more controversial than it might initially appear. In particular, the meaning of the phrase “not unduly discriminatory or preferential” is subject to widely differing interpretations. At a time when demand for electricity is increasing and utilities are building new power plants and transmission lines, a regulatory agency interested in minimizing total system costs may need to adopt a radically different perspective on DG than it has traditionally held in the past.
By far the most important factor that enters into the
determination of whether a DG project will be economically viable is the price that
the utility will pay for the power delivered to the electric grid. In
According to the Energy Dictionary, published online by EnergyVortex.com, the definition of avoided cost is as follows:
“Avoided cost is the marginal cost for the same amount of energy acquired through another means such as construction of a new production facility or purchase from an alternate supplier. For example, a megawatt-hour's avoided cost is the relative amount it would cost a customer to acquire this energy through the development of a new generating facility or acquisition of a new supplier. Short-run avoided cost refers to avoided cost calculated based on energy acquisition costs plus ongoing expenses. Long-run avoided cost factors in necessary long-term costs including capital expenditures for facilities and infrastructure upgrades. Avoided cost is typically used to calculate a fair price for energy produced by cogenerators and other energy producers that meet the specifications of the Public Utility Regulatory Policies Act of 1978. The use of avoided cost rates for cogenerated energy is intended to prevent waste and improve both efficiency and cleanliness by insuring that fair market prices paid for energy generated from renewable resources, small producers and others.”
The public utility commissions of various states have interpreted this definition in different ways. The Kentucky PSC has allowed utilities to establish unreasonable definitions of avoided cost in their tariffs that relate to the purchase of power from nonutility generators. A representative example is the LQF Tariff in effect for contracts between Kentucky Utilities Company and Large Capacity Cogeneration or Small Power Production Qualifying Facilities. The LQF tariff is applicable to any small power producer or cogeneration qualifying facility with capacity over 100 kW. The contract may be for the sale of energy, capacity, or both. The tariff includes formulas to calculate an energy component and a capacity component. The energy component is defined to be the hourly avoided energy cost, and consists of the utility’s average monthly fuel cost per MWh. Because the large majority of KU’s energy is generated from coal, the avoided energy cost will nearly always be approximately equal to the utility’s cost of coal per MWh. The amount the utility pays for the capacity component varies hourly, but is set equal to zero whenever the total demand of all of KU’s customers is less than KU’s total installed capacity, i.e., during the large majority of hours in a year. Because KU tries to maintain a reserve margin of 14% (Kentucky’s Electric Infrastructure: Present and Future, PSC, August 22, 2005, p.26), there are likely to be very few if any hours during the year when the capacity component is anything other than zero. Cogenerators considering a project in KU’s service territory cannot be confident of being paid much more for their electricity than KU’s average cost of fuel (i.e., coal) per MWh.
This interpretation of the meaning of avoided cost is flawed for several reasons.
1) As discussed above, the capacity component is
approximately zero. This reduces the
working definition of avoided cost to the short-run avoided cost. In
2) Even the definition of short-run avoided cost is being misinterpreted. The term “marginal cost” in the definition refers to the incremental cost of the next MWh needed, whereas the definition built into KU’s tariff calculates the energy component on the basis of the utility’s average cost of fuel. Utilities purchase much of their coal via long-term contracts. Although the price of coal fluctuates, the depletion of fossil fuels and the exhaustion of the most cheaply-mined coal reserves are certain to cause the real price to increase over time. We believe that the phenomenon known as Peak Oil will lead to a relentless increase in the price of oil, accompanied by increases in the price of the other fossil fuels, which are partial economic substitutes for oil. If Kentucky proceeds to build a significant capacity to convert coal into liquid fuels as envisioned by House Bill 299, which easily passed during the 2006 Regular Session of the General Assembly, then coal and oil will become closer economic substitutes, the demand for coal will increase, and the price of coal will track the price of oil more closely than it presently does. The marginal cost of coal, which would be approximated by the spot market price, will therefore usually be higher than the average cost of coal paid by a utility. A nonutility generator planning to burn coal would expect to pay a higher price for coal than a utility which obtains part of its coal through relatively low-priced long-term contracts. The definition of avoided cost embodied in KU’s LQF tariff disregards the concept of marginal cost.
3) The definition of avoided cost refers to the relative “cleanliness” of renewable energy sources. The PSC, however, has never placed any value on renewables’ relative lack of environmental impact compared to the mining and burning of fossil fuels. The KU tariff cited above gives no additional credit whatsoever for electricity generated from renewable energy sources. The tariff contravenes the intent of PURPA to encourage clean, renewable energy.
The corresponding tariff of KU’s affiliated company, LG&E, contains the same fatal flaws.
East Kentucky Power Co-op’s (EKPC) tariff for Cogeneration and Small Power Production Power Purchase Rate Schedule Over 100 kW has both an energy and a capacity component. To get an approximate idea of the relative size of these components, we hypothesized a DG resource with a net capacity of 200 kW that delivers its full production to the grid at a steady rate all year long. The total amount of energy delivered would be 1,753 MWh. Using EKPC’s buyback rates listed in the tariff for the year 2007, the total amount paid for energy would be $61,462, which would correspond to an average payment of 3.50 cents per kWh. If EKPC were to dispatch the power produced by the cogenerator, the amount paid for capacity would be $1,694 per year, while if EKPC does not dispatch the cogenerator, the amount paid for capacity would be $1,929 per year. In either case, the capacity component is negligible compared to the energy component. The DG facility would receive no credit for using less-polluting energy technologies.
AEP has a tariff for Cogeneration and/or Small Power Production over 100 kW. Assuming the same 200-kW DG resource as hypothesized above for EKPC, the amount paid for energy would be $49,280 per year – an average payment of 2.81 cents per kWh – and the amount paid for capacity would be a maximum of $3,865 per year. For this utility as well, the capacity component is dwarfed by the energy component. The DG facility would receive no credit for using less-polluting energy technologies.
To summarize, the DG buy-back rates that the PSC has established for the Commonwealth’s major electric utilities range from approximately 2 cents per kWh (as derived from KU/LG&E’s average cost of coal, and as reflected in its SQF tariff) to approximately 3.5 cents per kWh in the case of EKPC. The payment for capacity is nearly nonexistent, and the payment for environmental benefits is set precisely at zero.
In addition to the derisory buy-back rates that the
Commonwealth’s utility companies have established for DG via their tariffs,
utilities also frequently discourage potential cogeneration projects in more subtle
ways. When
Much of the testimony from utility companies in this case is consistent with the notion that DG is worth very little to the utility, to the system, and to other customers. In his testimony of 5/18/06, for example, Michael Leake of E.ON U.S. Services, which is affiliated with LG&E and KU, stated that “The impact of implementing the EPAct 2005 interconnection standard should not be significant, provided interconnected generation is not required to be incorporated into system resource plans due to its questionable availability, is not subsidized beyond avoided cost through rate incentives, and all associated costs of interconnection are assigned to the customers requesting interconnection.” (Testimony, p.1, lines 15-20) We know what Mr. Leake means by “avoided cost” from our discussion of KU’s LQF tariff above. Officials from other utilities raised similar alarms about DG’s costs and were similarly dismissive of its potential economic and environmental benefits. None of them mentioned the possibility that the benefits that DG could contribute to the system might significantly outweigh any costs it might cause.
There is a large amount of evidence that DG is actually
worth a great deal to the utility company and to society as a whole,
particularly during periods of increasing demand. In 2002 the Rocky Mountain Institute
published a revolutionary book called Small
Is Profitable, which describes a large number of economic benefits that
accrue to the system when small-scale, distributed generation is added to the
electric grid. When these benefits are
taken together, they far outweigh the additional utility costs that have been
emphasized by the utility personnel who have presented testimony in this
administrative case to date. Although
the executive summary of Small Is
Profitable is available on the internet via the web site http://www.smallisprofitable.org/index.html
, we are reprinting it here in its entirety because it is directly relevant to
the central issues of this case. The
factors discussed in the book relate both to EPACT 2005 Section 1254 on
interconnection and Section 1252 on time-based metering, and merit the closest
possible attention by the PSC and
Executive Summary – Small Is Profitable
“This book describes 207 ways in which the size of "electrical resources" – devices that make, save, or store electricity – affects their economic value. It finds that properly considering the economic benefits of "distributed" (decentralized) electrical resources typically raises their value by a large factor, often approximately tenfold, by improving system planning, utility construction and operation (especially of the grid), and service quality, and by avoiding societal costs.
“The actual increase in value, of course, depends strongly on the case-by-case technology, site, and timing. These factors are so complex that the distribution of value increases across the universe of potential applications is unknown. However, in many if not most cases, the increase in value should change investment decisions. For example, it should normally far exceed the cost differences between, say, modern natural-gas-fired power plants and windfarms. In many applications it could even make grid-interactive photovoltaics (solar cells) cost-effective today. It should therefore change how distributed resources are marketed and used, and it reveals policy and business opportunities to make these huge benefits explicit in the marketplace.
“The electricity industry is in the midst of profound and comprehensive change, including a return to the local and neighborhood scale in which the industry’s early history is rooted. Through the twentieth century, thermal (steam-raising) power stations evolved from local combined-heat-and-power plants serving neighborhoods to huge, remote, electricity-only generators serving whole regions. Elaborate technical and social systems commanded the flow of electrons from central stations to dispersed users and the reverse flow of money to pay for power stations, fuel, and grid. This architecture made sense in the early twentieth century when power stations were more expensive and less reliable than the grid, so they had to be combined via the grid to ensure reliable and economical supply. The grid also melded the diverse loads of many customers, shared the costly generating capacity, and made big and urban customers subsidize extension of electric service to rural customers.
“By the start of the twenty-first century, however, virtually everyone in industrialized countries had electric service, and the basic assumptions underpinning the big-station logic had reversed. Central thermal power plants could no longer deliver competitively cheap and reliable electricity through the grid, because the plants had come to cost less than the grid and had become so reliable that nearly all power failures originated in the grid. Thus the grid linking central stations to remote customers had become the main driver of those customers' power costs and power-quality problems – which became more acute as digital equipment required extremely reliable electricity. The cheapest, most reliable power, therefore, was that which was produced at or near the customers.
“Utilities'
traditional focus on a few genuine economies of scale (the bigger, the less
investment per kW) overlooked larger diseconomies of scale in the power
stations, the grid, the way both are run, and the architecture of the entire
system. The narrow vision that bigger is better ended up raising the costs and
financial risks that it was meant to reduce. The resulting disadvantages are
rooted in an enormous difference of scale between most needs and most supplies.
Three-fourths of
“The capital markets have gradually come to realize this. Central thermal power plants stopped getting more efficient in the 1960s, bigger in the '70s, cheaper in the '80s, and bought in the '90s. Smaller units offered greater economies from mass-production than big ones could gain through unit size. In the '90s, the cost differences between giant nuclear plants – the last gasp of '70s and '80s gigantism – and railcar-deliverable combined-cycle gas-fired plants, derived from mass-produced aircraft engines, created political stresses that drove the restructuring of the industry. At the same time, new kinds of "micropower" generators thousands or tens of thousands of times smaller – microturbines, solar cells, fuel cells, wind turbines – started to become serious competitors, often enabled by information and telecommunications technologies. The restructured industry exposed the previously sheltered power-plant builders to brutal market discipline. Competition from micropower, uncertain demand, and the inflexibility of big, slow-to-build plants created financial risk well beyond the capital markets' appetite. Then in 2001, longstanding concerns about the inherent vulnerability of giant plants and the far-flung grid were reinforced by the 9/11 terrorist attacks.
“The disappointing cost, efficiency, financial risk, and reliability of large thermal stations (and their associated grid investments) were leading their orders to collapse even before the cost difference between nuclear and combined-cycle costs stimulated restructuring that began to delaminate utilities. That restructuring created new market entrants, unbundled prices, and increased opportunities for competition at all scales – and thus launched the revolution in which swarms of microgenerators began to displace the behemoths. Already, distributed resources and the markets that let them compete have shifted most new generating units in competitive market economies from the million-kilowatt scale of the 1980s to the hundredfold-smaller scale that prevailed in the 1940s. Even more radical decentralization, all the way to customers' kilowatt scale (prevalent in and before the 1920s), is rapidly emerging and may prove even more beneficial, especially if it comes to rely on widely distributed microelectronic intelligence. Distributed generators do not require restructured electricity markets, and do not imply any particular scale for electricity business enterprises, but they are starting to drive the evolution of both.
“Some distributed technologies like solar cells and fuel cells are still made in low volume and can therefore cost more than competing sources. But such distributed sources' increased value – due to improvements in financial risk, engineering flexibility, security, environmental quality, and other important attributes – can often more than offset their apparent cost disadvantage. This book introduces engineering and financial practitioners, business managers and strategists, public policymakers, designers, and interested citizens to those new value opportunities. It also provides a basic introduction to key concepts from such disciplines as electrical engineering, power system planning, and financial economics. Its examples are mainly U.S.-based, but its scope is global.
“A handful of pioneering utilities and industries confirmed in the 1990s that distributed benefits are commercially valuable – so valuable that since the mid-'90s, most of the best conceptual analyses and field data have become proprietary, and government efforts to publish methods and examples of distributed-benefit valuation have been largely disbanded. Most published analyses and models, too, cover only small subsets of the issues. This study therefore seeks to provide the first full and systematic, if preliminary, public synthesis of how making electrical resources the right size can minimize their costs and risks. Its main findings are:
* The most valuable distributed benefits typically flow from financial economics – the lower risk of smaller modules with shorter lead times, portability, and low or no fuel-price volatility. These benefits often raise value by most of an order of magnitude (factor of ten) for renewables, and by about 3–5-fold for nonrenewables.
* Electrical-engineering benefits – lower grid costs and losses, better fault management, reactive support, etc. – usually provide another ~2–3-fold value gain, but more if the distribution grid is congested or if premium power quality or reliability are required.
* Many miscellaneous benefits may together increase value by another ~2-fold – more where waste heat can be reused.
* Externalities, though hard to quantify, may be politically decisive, and some are monetized.
* Capturing distributed benefits requires astute business strategy and reformed public policy.
“Emerging electricity market structures can now provide the incentives, the measurement and validation, and the disciplinary perspectives needed to give distributed benefits a market voice. Successful competitors will reflect those benefits in investment decisions and prices. Nearly a dozen other technological, conceptual, and institutional forces are also driving a rapid shift toward the "distributed utility," where power generation migrates from remote plants to customers' back yards, basements, rooftops, and driveways. This transformation promises a vibrantly competitive, resilient, and lucrative electricity sector, at less cost to customers and to the earth – thus fulfilling Thomas Edison’s original decentralized vision, just a century late.”
In order to begin to substantiate the dramatic economic claims made in this Executive Summary, we have included the book’s list of 207 benefits of distributed resources in this document as Attachment 1.
Returning to the clause in EPACT 2005 Section 1254 that
mandates that all interconnection “agreements and procedures shall be just and
reasonable, and not unduly discriminatory or preferential,” we must conclude
that the present regulatory climate in
The PSC and/or the General Assembly should mandate net metering – i.e, buyback rates equal to the retail rate the customer pays – for all DG projects that generate less pollution per unit of useful energy than the existing fleet of coal plants, and buyback rates significantly higher than the retail rate for DG technologies that are clean and renewable. The buyback rate of 15 cents per kWh for photovoltaic-generated electricity that is now in effect in the Tennessee Valley Authority’s service territory is not at all unreasonable. In addition, utilities should be happy to pick up all of the initial interconnection costs, because the net benefits that DG contributes to the system are so large. Contrary to the claims repeatedly made by the utility companies involved in this case, there is virtually no risk that other customers will end up subsidizing DG developers. In fact, it is highly likely that even with buyback rates set at the levels we suggest, DG facilities will provide enough economic benefits to the grid so as to constitute the subsidization of non-DG customers by DG developers.
III. Time-Based Metering and Communications
Section 1252 of EPAct 2005 lists four types of time-based rate schedules that help enable electric customers to manage energy use and cost through advanced metering and communications technology:
(i) time-of-use pricing such as seasonal rates that change twice each year;
(ii) critical peak pricing;
(iii) real-time pricing; and
(iv) credits for large customers that sign peak load reduction agreements with the utility.
The wholesale price of electricity varies considerably from hour to hour. During regional peak load periods, the price can vary by a factor of 100. One major source of economic inefficiency in the electricity market today is that most customers are completely disconnected from the price of the underlying commodity, the time-varying wholesale cost.
For reasons of economic efficiency, and in order to speed
the technological development of the grid in the directions outlined in the
Executive Summary of Small Is Profitable,
quoted above, the Cumberland Chapter of the Sierra Club supports an expansion
of the use of time-based metering and time-based rates. Real-time pricing (RTP) should be made
available to all large electricity customers in
The RTP program instituted by Georgia Power is an excellent model. This utility has the largest and most successful RTP program in the world, with over 1,600 participating customers and a demand response of 800 to 1,000 MW during high-price periods. More details about the program can be found in a December 2003 Electricity Journal article by Michael O’Sheasy titled, “Demand Response: Not Just Rhetoric, It Can Truly Be the Silver Bullet.”
These comments are respectfully submitted by Geoffrey Young
on behalf of the Cumberland Chapter of the Sierra Club at the public hearing
held at the PSC in
Attachment 1
207 Economic Benefits of Small
Distributed Generation Resources
From the book, Small Is Profitable, by Amory Lovins, et al., Rocky Mountain Institute.
1) Distributed resources' generally shorter construction period leaves less time for reality to diverge from expectations, thus reducing the probability and hence the financial risk of under- or overbuilding.
2) Distributed resources' smaller unit size also reduces the consequences of such divergence and hence reduces its financial risk.
3) The frequent correlation between distributed resources' shorter lead time and smaller unit size can create a multiplicative, not merely an additive, risk reduction.
4) Shorter lead time further reduces forecasting errors and associated financial risks by reducing errors' amplification with the passage of time.
5) Even if short-lead-time units have lower thermal efficiency, their lower capital and interest costs can often offset the excess carrying charges on idle centralized capacity whose better thermal efficiency is more than offset by high capital cost.
6) Smaller, faster modules can be built on a "pay-as-you-go" basis with less financial strain, reducing the builder's financial risk and hence cost of capital.
7) Centralized capacity additions overshoot demand (absent gross underforecasting or exactly predictable step-function increments of demand) because their inherent "lumpiness" leaves substantial increments of capacity idle until demand can "grow into it." In contrast, smaller units can more exactly match gradual changes in demand without building unnecessary slack capacity ("build-as-you-need"), so their capacity additions are employed incrementally and immediately.
8) Smaller, more modular capacity not only ties up less idle capital (#7), but also does so for a shorter time (because the demand can "grow into" the added capacity sooner), thus reducing the cost of capital per unit of revenue.
9) If distributed resources are becoming cheaper with time, as most are, their small units and short lead times permit those cost reductions to be almost fully captured. This is the inverse of #8: revenue increases there, and cost reductions here, are captured incrementally and immediately by following the demand or cost curves nearly exactly.
10) Using short-lead-time plants reduces the risk of a "death spiral" of rising tariffs and stagnating demand.
11) Shorter lead time and smaller unit size both reduce the accumulation of interest during construction—an important benefit in both accounting and cashflow terms.
12) Where the multiplicative effect of faster-and-smaller units reduces financial risk (#3) and hence the cost of project capital, the correlated effects—of that cheaper capital, less of it (#11), and needing it over a shorter construction period (#11)—can be triply multiplicative. This can in turn improve the enterprise's financial performance, gaining it access to still cheaper capital. This is the opposite of the effect often observed with large-scale, long-lead-time projects, whose enhanced financial risks not only raise the cost of project capital but may cause general deterioration of the developer's financial indicators, raising its cost of capital and making it even less competitive.
13) For utilities that use such accrual accounting mechanisms as AFUDC (Allowance for Funds Used During Construction), shorter lead time's reduced absolute and fractional interest burden can improve the quality of earnings, hence investors' perceptions and willingness to invest.
14) Distributed resources' modularity increases the developer's financial freedom by tying up only enough working capital to complete one segment at a time.
15) Shorter lead time and smaller unit size both decrease construction's burden on the developer's cashflow, improving financial indicators and hence reducing the cost of capital.
16) Shorter-lead-time plants can also improve cashflow by starting to earn revenue sooner—through operational revenue-earning or regulatory rate-basing as soon as each module is built—rather than waiting for the entire total capacity to be completed.
17) The high velocity of capital (#16) may permit self-financing of subsequent units from early operating revenues.
18) Where external finance is required, early operation of an initial unit gives investors an early demonstration of the developer's capability, reducing the perceived risk of subsequent units and hence the cost of capital to build them.
19) Short lead time allows companies a longer "breathing spell" after the startup of each generating unit, so that they can better recover from the financial strain of construction.
20) Shorter lead time and smaller unit size may decrease the incentive, and the bargaining power, of some workers or unions whose critical skills may otherwise give them the leverage to demand extremely high wages or to stretch out construction still further on large, lumpy, long-lead-time projects that can yield no revenue until completed.
21) Smaller plants' lower local impacts may qualify them for regulatory exemptions or streamlined approvals processes, further reducing construction time and hence financing costs.
22) Where smaller plants' lower local impacts qualify them for regulatory exemptions or streamlined approvals processes, the risk of project failure and lost investment due to regulatory rejection or onerous condition decreases, so investors may demand a smaller risk premium.
23) Smaller plants have less obtrusive siting impacts, avoiding the risk of a vicious circle of public response that makes siting ever more difficult.
24) Small units with short lead times reduce the risk of buying a technology that is or becomes obsolete even before it's installed, or soon thereafter.
25) Smaller units with short development and production times and quick installation can better exploit rapid learning: many generations of product development can be compressed into the time it would take simply to build a single giant unit, let alone operate it and gain experience with it.
26) Lessons learned during that rapid evolution can be applied incrementally and immediately in current production, not filed away for the next huge plant a decade or two later.
27) Distributed resources move labor from field worksites, where productivity gains are sparse, to the factory, where they're huge.
28) Distributed resources' construction tends to be far simpler, not requiring an expensively scarce level of construction management talent.
29) Faster construction means less workforce turnover, less retraining, and more craft and management continuity than would be possible on a decade-long project.
30) Distributed resources exploit modern and agile manufacturing techniques, highly competitive innovation, standardized parts, and commonly available production equipment shared with many other industries. All of these tend to reduce costs and delays.
31) Shorter lead time reduces exposure to changes in regulatory rules during construction.
32) Technologies that can be built quickly before the rules change and are modular so they can "learn faster" and embody continuous improvement are less exposed to regulatory risks.
33) Distributed technologies that are inherently benign (renewables) are less likely to suffer from regulatory restrictions.
34) Distributed resources may be small enough per unit to be considered de minimis and avoid certain kinds of regulation.
35) Smaller, faster modules offer some risk-reducing degree of protection from interest-rate fluctuations, which could be considered a regulatory risk if attributed to the Federal Reserve or similar national monetary authorities.
36) The flexibility of distributed resources allows managers to adjust capital investments continuously and incrementally, more exactly tracking the unfolding future, with continuously available options for modification or exit to avoid trapped equity.
37) Small, short-lead-time resources incur less carrying-charge penalty if suspended to await better information, or even if abandoned.
38) Distributed resources typically offer greater flexibility in accelerating completion if this becomes a valuable outcome.
39) Distributed resources allow capacity expansion decisions to become more routine and hence lower in transaction costs and overheads.
40) Distributed generation allows more learning before deciding, and makes learning a continuous process as experience expands rather than episodic with each lumpy, all-or-nothing decision.
41) Smaller, shorter-lead-time, more modular units tend to offer cheaper and more flexible options to planners seeking to minimize regret, because such resources can better adapt to and more cheaply guard against uncertainty about how the future will unfold.
42) Modular plants have off-ramps so that stopping the project is not a total loss: value can still be recovered from whatever modules were completed before the stop.
43) Distributed resources' physical portability will typically achieve a higher expected value than an otherwise comparable non-portable resource, because if circumstances change, a portable resource can be physically redeployed to a more advantageous location.
44) Portability also merits a more favorable discount rate because it is less likely that the anticipated value will not be realized—even though it may be realized in a different location than originally expected.
45) A service provider or third-party contractor whose market reflects a diverse range of temporary or uncertain-duration service needs can maintain a "lending library" of portable distributed resources that can achieve high collective utilization, yet at each deployment avoid inflexible fixed investments that lack assurance of long-term revenue.
46) Modular, standardized, distributed, portable units can more readily be resold as commodities in a secondary market, so they have a higher residual or salvage value than corresponding monolithic, specialized, centralized, nonportable units that have mainly a demolition cost at the end of their useful lives.
47) The value of the resale option for distributed resources is further enhanced by their divisibility into modules, of which as many as desired may be resold and the rest retained to a degree closely matched to new needs.
48) Distributed resources typically do little or no damage to their sites, and hence minimize or avoid site remediation costs if redeployed, salvaged, or decommissioned.
49) Volatile fuel prices set by fluctuating market conditions represent a financial risk. Many distributed resources do not use fuels and thus avoid that costly risk.
50) Even distributed resources that do use fuels, but use them more efficiently or dilute their cost impact by a higher ratio of fixed to variable costs, can reduce the financial risk of volatile fuel prices.
51) Resources with a low ratio of variable to fixed costs, such as renewables and end-use efficiency, incur less cost volatility and hence merit more favorable discount rates.
52) Fewer staff may be needed to manage and maintain distributed generation plants: contrary to the widespread assumption of higher per-capita overheads, the small organizations required can actually be leaner than large ones.
53) Meter-reading and other operational overheads may be quite different for renewable and distributed resources than for classical power plants.
54) Distributed resources tend to have lower administrative overheads than centralized ones because they do not require the same large organizations with broad capabilities nor, perhaps, more complex legally mandated administrative and reporting requirements.
55) Compared with central power stations, mass-produced modular resources should have lower maintenance equipment and training costs, lower carrying charges on spare-parts inventories, and much lower unit costs for spare parts made in higher production runs.
56) Unlike different fossil fuels, whose prices are highly correlated with each other, non-fueled resources (efficiency and renewables) have constant, uncorrelated prices that reduce the financial risk of an energy supply portfolio.
57) Efficiency and cogeneration can provide insurance against uncertainties in load growth because their output increases with electricity demand, providing extra capacity in exactly the conditions in which it is most valuable, both to the customer and to the electric service provider.
58) Distributed resources are typically sited at the downstream (customer) end of the traditional distribution system, where they can most directly improve the system's lowest load factors, worst losses, and highest marginal grid capital costs—thus creating the greatest value.
59) The more fine-grained the distributed resource—the closer it is in location and scale to customer load—the more exactly it can match the temporal and spatial pattern of the load, thus maximizing the avoidance of costs, losses, and idle capacity.
60) Distributed resources matched to customer loads can displace the least utilized grid assets.
61) Distributed resource matched to customer loads can displace the part of the grid that has the highest losses.
62) Distributed resources matched to customer loads can displace the part of the grid that typically has the biggest and costliest requirements for reactive power control.
63) Distributed resources matched to customer loads can displace the part of the grid that has the highest capital costs.
64) Many renewable resources closely fit traditional utility seasonal and daily loadshapes, maximizing their "capacity credit"—the extent to which each kW of renewable resource can reliably displace dispatchable generating resources and their associated grid capacity.
65) The same loadshape-matching enables certain renewable sources (such as photovoltaics in hot, sunny climates) to produce the most energy at the times when it is most valuable—an attribute that can be enhanced by design.
66) Reversible-fuel-cell storage of photovoltaic electricity can not only make the PVs a dispatchable electrical resource, but can also yield useful fuel-cell byproduct heat at night when it is most useful and when solar heat is least available.
67) Combinations of various renewable resources can complement each other under various weather conditions, increasing their collective reliability.
68) Distributed resources such as photovoltaics that are well matched to substation peak load can precool the transformer—even if peak load lasts longer than peak PV output—thus boosting substation capacity, reducing losses, and extending equipment life.
69) In general, interruptions of renewable energy flows due to weather can be predicted earlier and with higher confidence than interruptions of fossil-fueled or nuclear energy flows due to malfunction or other mishap.
70) Such weather-related interruptions of renewable sources also generally last for a much shorter time than major failures of central thermal stations.
71) Some distributed resources are the most reliable known sources of electricity, and in general, their technical availability is improving more and faster than that of centralized resources. (End-use efficiency resources are by definition 100% available—effectively, even more.)
72) Certain distributed generators' high technical availability is an inherent per-unit attribute—not achieved through the extra system costs of reserve margin, interconnection, dispersion, and unit and technological diversity required for less reliable central units to achieve the equivalent supply reliability.
73) In general, given reasonably reliable units, a large number of small units will have greater collective reliability than a small number of large units, thus favoring distributed resources.
74) Modular distributed generators have not only a higher collective availability but also a narrower potential range of availability than large, non-modular units, so there is less uncertainty in relying on their availability for planning purposes.
75) Most distributed resources, especially renewables, tend not only to fail less than centralized plants, but also to be easier and faster to fix when they do fail.
76) Repairs of distributed resources tend to require less exotic skills, unique parts, special equipment, difficult access, and awkward delivery logistics than repairs of centralized resources.
77) Repairs of distributed resources do not require costly, hard-to-find large blocks of replacement power, nor require them for long periods.
78) When a failed individual module, tracker, inverter, or turbine is being fixed, all the rest in the array continue to operate.
79) Distributed generation resources are quick and safe to work with: no post-shutdown thermal cooling of a huge thermal mass, let alone radioactive decay, need be waited out before repairs can begin.
80) Many distributed resources operate at low or ambient temperatures, fundamentally increasing safety and simplicity of repair.
81) A small amount of energy storage, or simple changes in design, can disproportionately increase the capacity credit due to intermittent renewable resources.
82) Distributed resources have an exceptionally high grid reliability value if they can be sited at or near the customer's premises, thus risking less "electron haul length" where supply could be interrupted.
83) Distributed resources tend to avoid the high voltages and currents and the complex delivery systems that are conducive to grid failures.
84) Deliberate disruptions of supply can be made local, brief, and unlikely if electric systems are carefully designed to be more efficient, diverse, dispersed, and renewable.
85) By blunting the effect of deliberate disruptions, distributed resources reduce the motivation to cause such disruptions in the first place.
86) Distributed generation in a large, far-flung grid may change its fundamental transient-response dynamics from unstable to stable—especially as the distributed resources become smaller, more widespread, faster-responding, and more intelligently controlled.
87) Modular, short-lead-time technologies valuably temporize: they buy time, in a self-reinforcing fashion, to develop and deploy better technologies, learn more, avoid more decisions, and make better decisions. The faster the technological and institutional change, and the greater the turbulence, the more valuable this time-buying ability becomes. The more the bought time is used to do things that buy still more time, the greater the leverage in avoided regret.
88) Smaller units, which are often distributed, tend to have a lower forced outage rate and a higher equivalent availability factor than larger units, thus decreasing reserve margin and spinning reserve requirements.
89) Multiple small units are far less likely to fail simultaneously than a single large unit.
90) The consequences of failure are far smaller for a small than for a large unit.
91) Smaller generating units have fewer and generally briefer scheduled or forced maintenance intervals, further reducing reserve requirements.
92) Distributed generators tend to have less extreme technical conditions (temperature, pressure, chemistry, etc.) than giant plants, so they tend not to incur the inherent reliability problems of more exotic materials pushed closer to their limits—thus increasing availability.
93) Smaller units tend to require less stringent technical reliability performance (e.g., failures per meter of boiler tubing per year) than very large units in order to achieve the same reliability (in this instance, because each small unit has fewer meters of boiler tubing)—thus again increasing unit availability and reducing reserves.
94) "Virtual spinning reserve" provided by distributed resources can replace traditional central-station spinning reserve at far lower cost.
95) Distributed substitutes for traditional spinning reserve capacity can reduce its operating hours—hence the mechanical wear, thermal stress, corrosion, and other gradual processes that shorten the life of expensive, slow-to-build, and hard-to-repair central generating equipment.
96) When distributed resources provide "virtual spinning reserve," they can reduce cycling, turn-on/shutdown, and low-load "idling" operation of central generating units, thereby increasing their lifetime.
97) Such life extension generally incurs a lower risk than supply expansion, and hence merits a more favorable risk-adjusted discount rate, further increasing its economic advantage.
98) Distributed resources can help reduce the reliability and capacity problems to which an aging or overstressed grid is liable.
99) Distributed resources offer greater business opportunities for profiting from hot spots and price spikes, because time and location-specific costs are typically more variable within the distribution system than in bulk generation.
100) Strategically, distributed resources make it possible to position and dispatch generating and demand-side resources optimally so as to maximize the entire range of distributed benefits.
101) Distributed resources (always on the demand side and often on the supply side) can largely or wholly avoid every category of grid costs on the margin by being already at or near the customer and hence requiring no further delivery.
102) Distributed resources have a shorter haul length from the more localized (less remote) source to the load, hence less electric resistance in the grid.
103) Distributed resources reduce required net inflow from the grid, reducing grid current and hence grid losses.
104) Distributed resources cause effective increases in conductor cross-section per unit of current (thereby decreasing resistance) if an unchanged conductor is carrying less current.
105) Distributed resources result in less conductor and transformer heating, hence less resistance.
106) Distributed resources' ability to decrease grid losses is increased because they are close to customers, maximizing the sequential compounding of the different losses that they avoid.
107) Distributed photovoltaics particularly reduce grid loss load because their output is greatest at peak hours (in a summer-peaking system), disproportionately reducing the heating of grid equipment.
108) Such onpeak generation also reduces losses precisely when the reductions are most valuable.
109) Since grid losses avoided by distributed resources are worth the product of the number times the value of each avoided kWh of losses, their value can multiply rapidly when using area- and time-specific costs.
110) Distributed resources can reduce reactive power consumption by shortening the electron haul length through lines and by not going through as many transformers—both major sources of inductive reactance.
111) Distributed resources can reduce current flows through inductive grid elements by meeting nearby loads directly rather than by bringing current through lines and transformers.
112) Some end-use-efficiency resources can provide reactive power as a free byproduct of their more efficient design.
113) Distributed generators that feed the grid through
appropriately designed
114) Reduced reactive current improves distribution voltage stability, thus improving end-use device reliability and lifetime, and enhancing customer satisfaction, at lower cost than for voltage-regulating equipment and its operation.
115) Reduced reactive current reduces conductor and transformer heating, improving grid components' lifetime.
116) Reduced reactive current, by cooling grid components, also makes them less likely to fail, improving the quality of customer service.
117) Reduced reactive current, by cooling grid components, also reduces conductor and transformer resistivity, thereby reducing real-power losses, hence reducing heating, hence further improving component lifetime and reliability.
118) Reduced reactive current increases available grid and generating capacity, adding to the capacity displacement achieved by distributed resources' supply of real current.
119) Distributed resources, by reducing line current, can help avoid voltage drop and associated costs by reducing the need for installing equipment to provide equivalent voltage support or step-up.
120) Distributed resources that operate in the daytime, when sunlight heats conductors or transformers, help to avoid costly increases in circuit voltage, reconductoring (replacing a conductor with one of higher ampacity), adding extra circuits, or, if available, transferring load to other circuits with spare ampacity.
121) Substation-sited photovoltaics can shade transformers, thereby improving their efficiency, capacity, lifetime, and reliability.
122) Distributed resources most readily replace distribution transformers at the smaller transformer sizes that have higher unit costs.
123) Distributed resources defer or avoid adding grid capacity.
124) Distributed resources, by reducing the current on transmission and distribution lines, free up grid capacity to provide service to other customers.
125) Distributed resources help "decongest" the grid so that existing but encumbered capacity can be freed up for other economic transactions.
126) Distributed resources avoid the siting problems that can occur when building new transmission lines.
127) These siting problems tend to be correlated with the presence of people, but people tend to correlate with both loads and opportunities for distributed resources.
128) Distributed resources' unloading, hence cooling, of grid components can disproportionately increase their operating life because most of the life-shortening effects are caused by the highest temperatures, which occur only during a small number of hours.
129) More reliable operation of distribution equipment can also decrease periodic maintenance costs and outage costs.
130) Distributed resources' reactive current, by improving voltage stability, can reduce tapchanger operation on transformers, increasing their lifetime.
131) Since distributed resources are nearer to the load, they increase reliability by reducing the length the power must travel and the number of components it must traverse.
132) Carefully sited distributed resources can substantially increase the distribution system operator's flexibility in rerouting power to isolate and bypass distribution faults and to maintain service to more customers during repairs.
133) That increased delivery flexibility reduces both the number of interrupted customers and the duration of their outage.
134) Distributed generators can be designed to operate properly when islanded, giving local distribution systems and customers the ability to ride out major or widespread outages.
135) Distributed resources require less equipment and fewer procedures to repair and maintain the generators.
136) Stand-alone distributed resources not connected to the grid avoid the cost (and potential ugliness) of extending and connecting a line to a customer's site.
137) Distributed resources can improve utility system reliability by powering vital protective functions of the grid even if its own power supply fails.
138) The modularity of many distributed resources enables them to scale down advantageously to small loads that would be uneconomic to serve with grid power because its fixed connection costs could not be amortized from electricity revenues.
139) Many distributed resources, notably photovoltaics, have costs that scale far more closely to their loads than do the costs of distribution systems.
140) Distributed generators provide electric energy that would otherwise have to be generated by a centralized plant, backed up by its spinning reserve, and delivered through grid losses to the same location.
141) Distributed resources available on peak can reduce the need for the costlier to-keep-warm centralized units.
142) Distributed resources very slightly reduce spinning reserves' operational cost.
143) Distributed resources can reduce power stations' startup cycles, thus improving their efficiency, lifetime, and reliability.
144) Inverter-driven distributed resources can provide extremely fast ramping to follow sudden increases or decreases in load, improving system stability and component lifetimes.
145) By combining fast ramping with flexible location, often in the distribution system, distributed resources may provide special benefits in correcting transients locally before they propagate upstream to affect more widespread transmission and generating resources.
146) Distributed resources allow for net metering, which in general is economically beneficial to the distribution utility (albeit at the expense of the incumbent generator).
147) Distributed resources may reduce utilities' avoided marginal cost and hence enable them to pay lower buyback prices to Qualifying Facilities.
148) Distributed resources' ability to provide power of the desired level of quality and reliability to particular customers—rather than just a homogeneous commodity via the grid—permits providers to match their offers with customers' diverse needs and to be paid for that close fit.
149) Distributed resources can avoid harmonic distortion in the locations where it is both more prevalent (e.g., at the end of long rural feeders) and more costly to correct.
150) Certain distributed resources can actively cancel harmonic distortion in real time, at or near the customer level.
151) Whether provided passively or actively, reduced harmonics means lower grid losses, equipment heating (which reduces life and reliability), interference with end-user and grid-control equipment, and cost of special harmonic-control equipment.
152) Appropriately designed distributed inverters can actively cancel or mitigate transients in real time at or near the customer level, improving grid stability.
153) Many distributed resources are renewable, and many customers are willing to pay a premium for electricity produced from a non-polluting generator.
154) Distributed resources allow for local control of generation, providing both economic-development and political benefits.
155) Certain distributed nonelectric supply-side resources such as daylighting and passive ventilation can valuably improve non-energy attributes (such as thermal, visual, and acoustic comfort), hence human and market performance.
156) Bundling distributed supply- with demand-side resources increases many of distributed generation's distributed benefits per kW, e.g., by improving match to loadshape, contribution to system reliability, or flexibility of dispatching real and reactive power.
157) Bundling distributed supply- with demand-side resources means less supply, improving the marketability of both by providing more benefits (such as security of supply) per unit of cost.
158) Bundling distributed supply- with demand-side resources increases the provider's profit or price flexibility by melding lower supply-side with higher demand-side margins.
159) Certain distributed resources can valuably burn local fuels that would otherwise be discarded, often at a financial and environmental cost.
160) Distributed resources provide a useful amount and temperature of waste heat conveniently close to the end-use.
161) Photovoltaic (or solar-thermal) panels on a building's roof can reduce the air conditioning load by shading the roof—thus avoiding air-conditioner and air-handling capacity, electricity, and the capacity to generate and deliver it, while extending roof life.
162) Some distributed resources like microturbines produce carbon dioxide, which can be used as an input to greenhouses or aquaculture farms.
163) Some types of distributed resources like photovoltaic tiles integrated into a roof can displace elements of the building's structure and hence of its construction cost.
164) Distributed resources make possible homes and other buildings with no infrastructure in the ground—no pipes or wires coming out—thus saving costs for society and possibly for the developer.
165) Because it lacks electricity, undeveloped land may be discounted in market value by more than the cost of installing distributed renewable generation—making that power source better than free.
166) Since certain distributed resources don't pollute and are often silent and inconspicuous, they usually don't reduce, and may enhance, the value of surrounding land—contrary to the effects of central power plants.
167) Some distributed resources can be installed on parcels of land that are too small, steep, rocky, odd-shaped, or constrained to be valuable for real-estate development.
168) Some distributed resources can be double-decked over other uses, reducing or eliminating net land costs. (Double-decking over utility substations, etc., can also yield valuable shading benefits that reduce losses (# 168) and extend equipment life.)
169) The shading achieved by double-decking PVs above parked cars or livestock can yield numerous private and public side-benefits.
170) Distributed resources may reduce society's subsidy payments compared with centralized resources.
171) Distributed resources can significantly—and when deployed on a large scale can comprehensively and profoundly—improve the resilience of electricity supply, thus reducing many kinds of social costs, risks, and anxieties, including military costs and vulnerabilities.
172) Technologies perceived as benign in their local impacts make siting approvals more likely, reducing the risk of project failure and lost investment and hence reducing the risk premium demanded by investors.
173) Technologies perceived as benign or de minimis in their local impacts can often also receive siting approvals faster, or can even be exempted from approvals processes, further shortening construction time and hence reducing financial cost and risk.
174) Technologies perceived as benign in their local impacts have wide flexibility in siting, making it possible to shop for lower-cost sites.
175) Technologies perceived as benign in their local impacts have wide flexibility in siting, making it easier to locate them in the positions that will maximize system benefits.
176) Siting flexibility is further increased where the technology, due to its small scale, cogeneration potential, and perhaps nonthermal nature, requires little or no heat sink.
177) Distributed resources' local siting and implementation tend to increase their local economic multiplier and thereby further enhance local acceptance.
178) Distributed resources can often be locally made, creating a concentration of new skills, industrial capabilities, and potential to exploit markets elsewhere.
179) Most well-designed distributed resources reduce acoustic and aesthetic impacts.
180) Distributed resources can reduce irreversible resource commitments and their inflexibility.
181) Distributed resources facilitate local stakeholder engagements and increase the community's sense of accountability, reducing potential conflict.
182) Distributed resources generally reduce and simplify public health and safety impacts, especially of the more opaque and lasting kinds.
183) Distributed resources are less liable to the regulatory "ratcheting" feedback that tends to raise unit costs as more plants are built and as they stimulate more public unease.
184) Distributed resources are fairer, and seen to be fairer, than centralized resources because their costs and benefits tend to go to the same people at the same time.
185) Distributed resources have less demanding institutional requirements, and tend to offer the political transparency and attractiveness of the vernacular.
186) Distributed resources lend themselves to local decisions, enhancing public comprehension and legitimacy.
187) Distributed resources are more likely than centralized ones to respect and fit community and jurisdictional boundaries, simplifying communications and decision-making.
188) Distributed resources better fit the scale of communities' needs and ability to address them.
189) Distributed resources foster institutional structure that is more weblike, learns faster, and is more adaptive, making the inevitable mistakes less likely, consequential, and lasting.
190) Distributed resources' smaller, more agile, less bureaucratized institutional framework is more permeable and friendly to information flows inward and outward, further speeding learning.
191) Distributed resources' low cost and short lead time for experimental improvement encourages and rewards more of it and hence accelerates it.
192) Distributed resources' size and technology (frequently well correlated) generally merit and enjoy a favorable public image that developers, in turn, are generally both eager and able to uphold and enhance, aligning their goals with the public's.
193) With some notable exceptions such as dirty engine generators, distributed resources tend to reduce total air emissions per unit of energy services delivered.
194) Since distributed resources' air emissions are directly experienced by the neighbors with the greatest influence on local acceptance and siting, political feedback is short and quick, yielding strong pressure for clean operations and continuous improvement.
195) Due to scale, technology, and local accountability informed by direct perception, the rules governing distributed resources are less likely to be distorted by special-interest lobbying than those governing centralized resources.
196) Distributed utilities tend to require less, and often require no, land for fuel extraction, processing, and transportation.
197) Distributed resources' land-use tends to be temporary rather than permanent.
198) Distributed resources tend to reduce harm to fish and wildlife by inherently lower impacts and more confined range of effects (so that organisms can more easily avoid or escape them).
199) Some distributed resources reduce and others altogether avoid harmful discharges of heat to the environment.
200) Some hydroelectric resources may be less harmful to fish at small than at large scale.
201) The greater operational flexibility of some distributed resources, and their ability to serve multiple roles or users, may create new opportunities for power exchange benefiting anadromous fish.
202) Well-designed distributed resources are often less materials- and energy-intensive than their centralized counterparts, comparing whole systems for equal delivered production.
203) Distributed resources' often lower materials and energy intensity reduces their indirect or embodied pollution from materials production and manufacturing.
204) Many distributed resources' reduced materials intensity reduces their indirect consumption of depletable mineral resources.
205) The small scale, standardization, and simplicity of most distributed resources simplifies their repair and may improve the likelihood of their remanufacture or recycling, further conserving materials.
206) Many distributed resources withdraw and consume little or no water.
207) Many distributed resources offer psychological or social benefits of almost infinite variety to users whose unique prerogative it is to value them however they choose.
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