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The report argues that rate-regulated utilities use 'self-commitment' to bypass market merit order, running coal plants that are objectively uneconomic and passing the resulting losses to captive customers through state fuel-cost-recovery processes. Using PLEXOS modeling for the MISO region in 2018, the authors find that this practice cost customers $350 million and suppressed regional market clearing prices by 2.4%. The report identifies Cleco and DTE Energy as significant contributors to these distortions and recommends that state regulators disallow the recovery of imprudent, above-market costs to incentivize efficient dispatch.

The paper argues that the variability of renewable energy can be managed through optimized geographic dispersion and the cross-firming of wind and solar resources. By analyzing data from the MRO, SPP, and ERCOT regions, the study demonstrates that expanding the geographic scope of a renewable portfolio significantly reduces system variability and the frequency of zero-power production. It also finds that combining solar and wind resources further lowers variability compared to wind-only portfolios. The authors conclude that these strategies, combined with demand response, energy storage (such as xEVs), and smart grid communications, can reduce the reliance on conventional baseload power.