McCullough Research frequently lends its opinions and expertise to a wide range of issues across the energy industry. Here is a sample of some opinion pieces, essays, and articles contributed by Robert McCullough in recent years.

1998, 1999, 2001, 2002, 2003, 2005, 2006, 2008, 2009, 2012, 2013, 2014, 2015, 2016, 2017, 2019, 2020, 2021, 2022


March 31, 2022
Whither Hydro-Québec?

The Lawyer’s Daily, Robert McCullough

High above René Lévesque Boulevard in Montreal looms the redoubt of Hydro-Québec — long one of the most secretive utilities in North America. While resource plans at other utilities in Canada and the U.S. can run to thousands of pages — including detailed studies of markets, technologies, loads and transmission — Hydro-Québec’s periodic Strategic Plans have slowly but surely shrunk to a minimalist report announcing their existence, their profound popularity and their contribution to the Quebec economy.

In March, the tiniest glimmer of information was released from la
forteresse d’Hydro-Québec.

March 8, 2022
Increasing U.S. Oil Production During Ukraine Invasions

DC Report, Robert McCullough

Successful oil sanctions against Russia will cause less harm to the world economy if U.S. oil production ramps up. Unfortunately, the U.S. response to high oil prices has been slow and cautious. To meet needs in Europe, the U.S. may need to consider financing support for independent wildcatters in mid-continental oil fields to accelerate U.S. oil production


December 23, 2021
One Tomb Raider Good: Two Tomb Raiders Better

The Lawyer’s Daily, Robert McCullough

The poorly drafted New York contract will probably face many of the same problems that the similarly drafted contract with Massachusetts has had in New Hampshire and Maine. The lack of transparency creates suspicions, the lack of co-operation creates enemies, and the lack of environmental substance creates opponents. All three problems are relatively easy to solve — however, I think we will find that if one tomb raider is good, two are better is the wrong model.


October, 2020
Exactly How Inefficient is the PJM Capacity Market?

The Electricity Journal, Robert McCullough

A peculiar feature of the PJM RTO is its segmented capacity market, where pivotal suppliers have successfully petitioned to separate from the larger market and create captive Locational Deliverability Areas (LDAs) in which they have a dominant market share. We analyze the competitiveness of the market, the growing capacity margins, as well as the PJM LDA market concentration via Hirschfield-Herfindahl Index (HHI), 4-Firm Concentration Ratio (CR4) and Three- Pivotal-Supplier (TPS) test.

April 1, 2020
FERC’s MOPR Dissected

Public Utilities Fortnightly, Robert McCullough

The two leading renewable technologies are non-dispatchable intermittent resources. The unsubstantiated assumption that they will lower the value of capacity needs to be examined closely.


November 8, 2019
Why have PJM capacity markets decoupled from actual capacity bids?

The Electricity Journal, Robert McCullough

We analyze PJM’s Reliability Pricing Model auction in the context of ongoing reform proposals that seek to address the perception that state subsidies for carbon free generation are depressing capacity prices.

August 28, 2019
Oregon natural gas facility could be fuelled by Canadian sources

The Lawyer’s Daily, Robert McCullough

Jordan Cove is planned for Coos Bay. In order to procure natural gas, a pipeline is planned to connect to supplies at Malin, Ore. Malin connects to Kingsgate, Alta., and Opal, Wyo. Overall, Coos Bay is over 909 miles from sources of supply in the east and 841 miles from Alberta.

August 2019
The Hidden Killer: Towards Regulating Railyard Diesel Particulate Matter Emissions in Oregon

Hatfield Graduate Journal of Public Affairs, Robert McCullough

We summarize the health impacts of diesel particulates emitted from railyards in Oregon. Using the most conservative range of the EPA’s assessment, we calculate a Pigouvian Tax for the railroad companies to pay, totaling $624.24 per μg/m3 for each person in the affected area.

March 1, 2019
The End of Big Iron: How Wind and Solar Became Cheaper than Hydro, Coal, and Nuclear

Public Utilities Fortnightly, Robert McCullough

Since the electrification of North America commenced at the start of the last century, the industry has focused on big iron. Larger projects offered efficiency in location and economies of scale. The end of this era is rapidly approaching as smaller, more maneuverable, and less expensive options take the center stage in electric utility planning.

January 23, 2019
The End of Big Hydro

The Lawyer’s Daily, Robert McCullough

From the Tennessee to the Columbia rivers, hydroelectric dams have played a decisive role in making cheap electricity widely distributed throughout the North American economy. From declining fish populations to flooded land, some Canadians and Americans have had to pay a higher price to make hydro power possible.

That social trade-off is making less sense today as the levelized cost of energy (LCOE) from wind and solar generation has now dropped below the LCOE of hydro and most all thermal energy resources. The portion of a U.S. state’s power generation by hydro no longer predicts its electricity prices.


December 26, 2017
Taking the path less followed

The Vancouver Sun, Robert McCullough

A month ago, I had the honour of sitting down with the NDP cabinet and Premier John Horgan. I gave a detailed presentation why proceeding with Site C would be costly and risky. Curiously, after the cabinet meeting the only followup involved questions from specific MLAs — not inquiries from the cabinet or their staff.

October 30, 2017
Opinion: Site C proponents fall prey to sunk cost fallacy

The Vancouver Sun, Robert McCullough

Recently, professors Shaffer and Richards recommended finishing the costly Site C project in order to reduce carbon emissions in Alberta. This proposal compounds the sunk-costs fallacy with a curious desire to ship expensive electricity to Alberta — where much-cheaper alternatives are also available.

September 19, 2017
Opinion: Renewables cheaper, more dependable that Site C

The Vancouver Sun, Robert McCullough

The problem with Site C is not that it is a hydroelectric project. The problem with Site C lies in the economics. When Site C was proposed, fossil fuel prices were high. The cost of renewables were twice what they are now. Loads were not increasing terribly rapidly (load growth has been flat in B.C. for the past decade), but the forecasts were very optimistic. It is not an exaggeration to say that everything has changed. Site C is relatively costly compared to the alternatives and very costly compared to the wholesale market. It is in our power to do far more and spend far less.

June 22, 2017
Trump plan to sell BPA lines misguided

Portland Tribune, Robert McCullough

“Privatization of BPA would increase costs for consumers. BPA currently sells and delivers its power at cost; under a private regime, an investor-owned utility would likely want a higher rate of return.”

April 11, 2017
Affordable power or Site C power: British Columbians must choose

Business Vancouver, Robert McCullough and Gwen Johansson

“By choosing cheaper alternatives, British Columbians not only avoid amassing billions of dollars of debt, they also spare a valley capable of feeding a million people in perpetuity, maintain a wildlife ‘nursery’ that has existed for thousands of years and honour First Nation treaty commitments. The choice is a win-win for B.C. ratepayers and, ultimately, for our Crown corporation.”

February 28, 2017
My View: Trade tariffs would hurt Americans

The Portland Tribune, Robert McCullough

“There is little new about Trump’s argument. It is the same vacuous idea that Adam Smith’s “Wealth of Nations” rejected 240 years ago. Free trade was good policy then, and it continues to be good policy today.”

January 8, 2017
Many lives of Jordan Cove may have come to an end

The Oregonian, Robert McCullough, Charles Noble, and Jacob Gellman

“Liquefied Natural Gas (LNG) facilities, like cats, are known to have many lives. They also have a tendency to land on their feet after a fall. The Jordan Cove LNG proposal has survived many regulatory and market setbacks in its thirteen-year life. However, the question remains: Can it survive a dour market and more efficient competitors?”


July 22, 2016
Balancing an aging Hanford nuke plant against cheaper firm market power purchases

The Oregonian, Robert McCullough

“Recent closure announcements in California, Florida, Nebraska, Wisconsin, Vermont, Illinois, New York, New Jersey and Massachusetts all reflect the same underlying economic issue. Older nuclear units are proving more expensive than alternatives. The hundreds of millions we lose every year by operating this elderly power plant can be put to far better use elsewhere.”

July 7, 2016
More roads needed to handle growth

The Portland Tribune, Robert McCullough

“Growth contributes to the overall health of the community, even when infrastructure requires investment.”

July 7, 2016
Close the expensive Columbia Generating Station

The Oregonian, Robert McCullough

“Reports from many unimpeachable sources now indicate that renewables will be less expensive than the operating costs of WPPSS 2. These include the recent reports from the U.S. National Renewable Energy Laboratory, Lazard’s annual review of power costs, and the studies supporting the closure of California’s Diablo Canyon nuclear power plant.”

June 29, 2016
Our future is in green energy, not aging, costly nuclear plants
The Seattle Times, Robert McCullough

“Washington State’s nuclear power plant — WPPSS 2 — is a relic of an energy plan begun in the 1960s and built with technology from the 1970s. It is an 8-Track tape player in an iPad world.”

May 12, 2016
Diesel tax on heavy trucks is right move
The Portland Tribune, Robert McCullough

“Over the past 50 years, the real tax per gallon — both gasoline and diesel — has declined by one-third. Total road mileage in use is harder to find, but we do know that it has increased by 20 percent since the 1990s.”

May 2016
Aspirational Planning: A Statistical Model of Hawthorne Bridge and Tilikum Crossing Bicycle Ride Counts
Hatfield Graduate Journal of Public Affairs, Robert McCullough, Ramon Cabautan, Jacob Gellman

“The authors present an ordinary least squares model to explain bicycle ridership on the Hawthorne Bridge and the recently constructed Tilikum Crossing. When controlling for other factors such as weather and daylight, the Tilikum Crossing has added an average of 1,137 bicycle rides per day to total east-west rides across the Willamette River, some of which are diverted from the Hawthorne Bridge.”

January 19, 2016
A good time for a sensibly managed Portland gas tax
The Oregonian, Robert McCullough

“The arguments for a gas tax increase are compelling. … In case the price shock at the pump has faded from our collective memories, retail gasoline prices are roughly half the level we paid five years ago. This is a tremendous windfall, and some, at least, should be put to a good use.”


October 15, 2015
A plan to fix Portland’s roads
The Oregonian, Robert McCullough

“How did the transportation hub of Oregon and Washington get such bad roads? Stripped of the rhetoric, Portland’s streets are the moral equivalent of the back yard shed you never get around to repainting.”


December 2014
Nuclear Winter
Electricity Policy, Robert McCullough, Garrett Oursland, Rose Anderson

“The problems facing the nuclear industry are national in scope and appear to be enduring in effect. Only a major change in the economics of the industry is likely to avoid market-based nuclear plant closures in years to come.”


August 22, 2013
Transparency in fuel pricing is long overdue
Capitol Journal, Robert McCullough

Robert McCullough argues that price transparency is required in other energy markets like electricity and natural gas, and it is about time that similar rules are applied to gasoline markets.

April 2013
It’s time to consider a less-costly U.S. energy plan
The Oregonian, Opinion Editorial, Robert McCullough

Robert McCullough critiques United States national energy policy. He argues that oil is both less regulated than and more expensive than other fuels, and yet the United States continues to export domestic coal and natural gas at cheap prices. In the end, McCullough puts forth a two-point strategy that would address these issues.


November 2012
Are electric vehicles actually cost-effective?
Electricity Policy, Robert McCullough

Robert McCullough responds to a study by the Congressional Budget Office which found that electric vehicles are not cost effective. He refutes a series of crucial assumptions which were posited by the CBO. After introducing and justifying a set of new assumptions, McCullough finds that electric vehicles are cost-effective across broad ranges in the price of batteries, gasoline, and electricity.

November 2012
Portland’s energy credits: The trouble with buying ‘green’
The Oregonian, Opinion Editorial, Robert McCullough

Robert McCullough criticizes Portland Mayor Sam Adams for the purchase of renewable energy credits. He argues that such an action by a city is, in fact, a waste of city resources. If the city of Portland wants to decrease dependence on fossil fuels, McCullough argues, they ought to promote the use of electric vehicles. — The Oregonian, Opinion Editorial, Robert McCullough

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July 2009
Fingerprinting the Invisible Hands
Public Utilities Fortnightly, Robert McCullough

Robert McCullough discusses how opaque markets inflate power prices: “In the administered North American electricity markets, a high level of secrecy concerning bids, bidders, and computations is currently the norm. The decision to maintain such secrecy has little discussion and the impacts of secrecy on prices and efficiency have never been comprehensively studied. One of the very few surveys of transparency in this area, a CRA report prepared in 2007, concludes that ‘[f]ew, if any, of the markets had evaluated information disclosure explicitly for its effects on competition or market efficiency.’ In practice, the issue of transparency has been left to Adam Smith’s ‘invisible hands.’

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February 2008
The High Cost of Restructuring
Public Utilities Fortnightly, Robert McCullough, Berne Martin Howard and Michael Deen

RTO Markets aren’t living up to the promise of cheap power.

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March 27, 2006
A Decisive Time for LNG
Daily Astorian, Opinion Editorial, Robert McCullough and Ann Stewart

LNG’s place in an efficient energy economy.

February 15, 2006
Utilities and Trade Secrets: Retain the Openness in Utility Regulation
The Oregonian, Opinion Editorial, Robert McCullough

The importance of public accessibility to information about utilities’ operations and infrastructure.

February 9, 2006
Opening the Books
The Oregonian, Opinion Editorial, Robert McCullough

“Enron, in spite of recent evidence, will eventually fade away. The issue that lawyers and economists call transparency — openness — will not. The basic protections for consumers and investors have against fraud is information. . . The best way to avoid a repetition of such schemes is to make sure that public policy in Oregon continues to provide the citizens of Oregon with open information on the operations of the electric infrastructure that is critical for their lives.”

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August 2, 2005
Squeezing Scarcity from Abundance
Public Utilities Fortnightly, Robert McCullough

Analyzes the California Energy Crisis and critiques regulatory attempts.


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March 25, 2003
Revisiting California
Public Utilities Fortnightly, Robert McCullough

A follow-up to Price Spike Tsunami: How Market Power Soaked California: “the crisis turned out to be a problem in institutions and not resources”, and “California’s restructuring was characterized by six words – ‘bad design, bad incentives, bad results’.”

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July 9, 2002
Opinion Editorial
Seattle Times, Opinion Editorial, Robert McCullough

Analyzes Seattle City Light’s actions during the California crisis.

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February 1, 2001
Letter to the Governor: What Oregon Should Know About the ISO
Public Utilities Fortnightly, Robert McCullough

“The Federal Energy Regulatory Commission’s Dec. 15 order proposing remedies for calming runaway prices in the western power markets was largely disconnected from the ongoing crisis. . . . The result, amply shown in this order, has been to cancel the parts of the experiment that do not agree with FERC’s beliefs, without really focusing on the underlying problems.”

January 1, 2001
Price Spike Tsunami: How Market Power Soaked California
Public Utilities Fortnightly, Robert McCullough

Cover story article detailing market power abuses in California.

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March 1, 1999
Electric Competition, One Year Later: Winners and Losers in California
Public Utilities Fortnightly, Robert McCullough

“California’s Electric Restructuring Plan, launched April 1, 1998, marks one of the most ambitious attempts in U.S. history to place the state in a social engineering role.” How has the experiment gone?

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July 15, 1998
California’s Electricity Market: Are Customers Necessary? Why Competitive energy suppliers see retail consumers as a burden under the current rules
Public Utilities Fortnightly, Robert McCullough

“A careful review shows that the California Public Utilities Commission, guided by the torturous language of Assembly Bill 1890, the state’s electric restructuring law, has created a situation where customers are not necessarily a part of a competitive market. While that may sound peculiar, not to say counterproductive, it simply reflects the PUC’s preoccupation with theoretical market issues and its lack of interest in short-term customer welfare. As the PUC has stated many times, its major interest was in achieving a transparent pricing and market structure. It may well have succeeded but at the cost of giving up market access for the customers themselves.”

March 15, 1998
Can Electricity Markets Work Without Capacity Prices?
Public Utilities Fortnightly, Robert McCullough

“Many players in the electric industry have come to believe that energy-only prices will soon replace the hundred-year tradition of pricing both energy and capacity. This idea, sometimes called “monomic” trading, offers a seductive simplicity. Even so, research indicates that it is unlikely to work well.”

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