In their paper, Managing the Future of the Electricity Grid: Energy Storage and Greenhouse Gas Emissions, Richard L. Revesz and Burcin Unel of New York University School of Law (NYU team or authors) highlight a critical (and often times contentious) issue that the energy industry is attempting to address: how to quantify and incorporate a societal value of decreased greenhouse gas emissions into the dollar value of incremental energy that is provided to the electric system. The NYU team has appropriately noted that this discussion becomes more complex when one considers the ability of energy storage to withdraw energy in real time to be injected when it can be better utilized later. This capability has the potential to change the way “marginal” energy is defined.