What type of regulation when?

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I like this taxonomy of what type of regulatory/liability framework to use in which situation posted in Environmental Economics. (Reminds me of a market-type structure I created for my 1996 paper on environmental commodity markets.) However, I think the two choices on the right side could be changed:

  • Lower right corner to “incentive-based regulation”: The damages are clear and can be valued, but engaging in market transactions is costly. For example, energy efficiency has a clear value with significant spill over benefits, but the costs of gaining information about net gains is costly for individuals. So setting an incentive standard for manufacturers or in energy rates is more cost effective.
  • Upper right corner to “command and control regulation”: The damages are known and significant, but quantifying them economically, or even physically, is difficult. There are no opportunities for market transactions, but society wants to act. In this case, the regulators would set bounds on behavior or performance.
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Ahead of the tariff, U.S. imported 3 years worth of solar panels from China

1024x1024Panel imports were up 1,200 percent in fourth quarter 2017. That implies that installers were banking supplies to ride out the import tariff imposed by the Trump Administration. Unfortunately, it also means that the rapid technical and cost progress for panels may stall for that three year period.

Electric industry tries the “big lie”

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The Edison Electric Institute has floated the idea that demand charges should be renamed as “efficiency rates.” Demand charges measure the maximum use in a month, and once a customer reaches that demand level in a month, a portion of the usage is free below that demand level. Providing power for free encourages more use, not less, which is the opposite of what “efficiency rates” should do.  Apparently this proposal is part of a larger effort to relabel everything that utilities find objectionable, such as distributed energy resources.

Demand charges can have a place in rate making, but the best such tool, made feasible by the rollout of “smart meters,” is daily demand charges that reset each day.

 

Commentary on CPUC Rate Design Workshop

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The California Public Utilities Commission (CPUC) held a two-day workshop on rate design principles for commercial and industrial customers. To the the extent possible, rates are designed in California to reflect the temporal changes in underlying costs–the “marginal costs” of power production and delivery.

Professor Severin Borenstein’s opening presentation doesn’t discuss a very important aspect of marginal costs that we have too long ignored in rate making. That’s the issue of “putty/clay” differences. This is an issue of temporal consistency in marginal cost calculation. The “putty” costs are those short term costs of operating the existing infrastructure. The “clay” costs are those of adding infrastructure which are longer term costs. Sometimes the operational costs can be substitutes for infrastructure. However we are now adding infrastructure (clay) in renewables have have negligible operating (putty) costs. The issue we now face is how to transition from focusing on putty to clay costs as the appropriate marginal cost signals.

Carl Linvill from the Regulatory Assistance Project (RAP) made a contrasting presentation that incorporated those differences in temporal perspectives for marginal costs.

Another issue raised by Doug Ledbetter of Opterra is that customers require certainty as well as expected returns to invest in energy-saving projects. We can have certainty for customers if the utilities vintage/grandfather rates and/or structures at the time they make the investment. Then rates / structures for other customers can vary and reflect the benefits that were created by those customers making investments.

Jamie Fine of EDF emphasized that rate design needs to focus on what is actionable by customers more so than on a best reflection of underlying costs. As an intervenor group representative, we are constantly having this discussion with utilities. Often when we make a suggestion about easing customer acceptance, they say “we didn’t think of that,” but then just move along with their original plan. The rise of DERs and CCAs are in part a response to that tone-deaf approach by the incumbent utilities.

Paying off coal miners to improve the environment

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Finally, a real world example of how benefit-cost analysis should be used in practice. Alberta takes the revenues that represent a portion of the society wide benefits and distributes those to the losers from the policy change. Economists have almost always ignored the problem of how to compensate losers in changes in social policy, and of course those who keep losing increasingly oppose any more policies. Instead of dreaming up ways to invest carbon market revenues in whiz bang solutions, we first need to focus on who’s being left behind so they are not resentful, and become a key political impediment to doing the right thing.

Trivializing the risks of climate change

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The Guardian

I follow Matthew Kahn’s, USC economics chair, blog posts. He expresses a libertarian view. He also writes about climate adaptation. He makes an important point that civilization is not static and we will be able to adapt the human ecology to a range of climate change. But his latest post on how climate change might affect marathon performances raised an important issue for me.

Kahn fails to acknowledge that adaptation to small, incremental climate change is not the concern. It’s the large, catastrophic changes with unknown (and unknowable) probability–deep uncertainty–that is of concern–collapsing ice sheets or ecosystems. He is not addressing the problem of what happens if the climate passes a tipping point. These types of articles and blog posts produced by Kahn and his colleagues trivialize the real risks and consequences, as though we’re just trying to adapt to a change in the weather while ignoring the potential systemic changes.

California utilities continue to ask ratepayers to shoulder more and more risk

Wine Country wildfires may have been caused by PG&E electrical lines.

PG&E proposed to the California Public Utilities Commission in an ex parte meeting with a Commissioner that ratepayers rather than shareholders should bear the liability costs from the Wine Country fires. This is part of a larger pattern where the investor-owned utilities have pushed off procurement and management risks onto ratepayers. Yet, the IOUs continue to ask for investor returns that reflect much higher shareholder risks at 14% pre-tax.

If ratepayers are not getting the single most important benefit from investor-owned utilities–that is risk insurance–then it may be time to consider cutting our the middleman–the shareholder–and just go with public ownership. In the end, it looks like there will be no real differences in costs and risks, and we are no longer unduly enriching the wealthy who hold shares in the utilities.