Why the CPUC’s RA Market Report gives the wrong reliability price metric


In its annual report on resource adequacy (RA) transactions, the CPUC reports the wrong result for the market price to be used for valuing capacity from the RA market data. The Commission’s decision issued in the PCIA rulemaking on establishing the CCA’s “exit fee” uses this value in error. In the CAISO energy and ancillary services markets, the market clearing price used to set the value of the energy portfolio is determined by the highest accepted bid in a single hour, and then averaged across all hours. In contrast, the average reported RA price in The 2017 Resource Adequacy Report incorrectly reports the average of all transactions. This would be equivalent to the CAISO reporting the average of all accepted bids, including those at zero or even negative, as the market clearing price.

The appropriate RA price metric is the highest RA transaction price for each month. This price represents the market equilibrium point at which a consumer is willing to pay the highest price given how low a price a supplier is willing to provide that quantity of the resource. (The other transactions are called “inframarginal” and such transactions are common in many markets.) In a full auction market, all transactions would clear at this single price, which is why the CAISO reports a single market clearing price for all transactions in a single hour. That should also be the case for the RA market price, except the time unit is a month.

Due to a lack of an auction for the moment, it is possible to manipulate the highest apparent price through a bilateral transaction. Instead, the Commission could choose a price near the highest point, but with sufficient market depth to mitigate potential manipulation. Using the 90th percentile transaction is one metric commonly used based on a quick survey of market price reports.


Why the CPUC has it wrong on the PCIA

Nick Chaset is the CEO of East Bay Community Energy which is a community choice aggregator (CCA) that serves Alameda County. He also was Commission President Michael Picker’s chief advisor until last year when he left for EBCE. He explains in this article how two proposed decisions that the CPUC is considering are fundamentally wrong and will shift cost onto CCA customers. (I testified on behalf of CalCCA in this proceeding. I’ll have more on this before the Commission’s scheduled vote October 11.)

Figure 1 – CPUC’s Proposed Resource Adequacy Value vs. True Market Values


Figure 2 – GHG Premium Value Missing from CPUC Proposed Decision


Figure 3 – Falling Utility Rates as Customers Depart Filed in Their ERRA Rate Applications



MIT tries to resurrect nuclear power


I received a notice of a new MIT study entitled “The Future of Nuclear Energy in a Carbon-Constrained World” which looks at the technological, regulatory and economic changes required to make nuclear power viable again. A summary states

The findings are that new policy models and cost-cutting technologies would help nuclear play vital role in climate solutions. Progress in reducing carbon emissions requires a broad range of actions to effectively leverage nuclear energy.

However, nothing in the summary reveals the paradigm-shattering innovation that will be required to make nuclear power competitive with a diverse fleet of renewables plus storage that would achieve the same goals. The cost of a solar plant plus storage with today’s technology still costs less than a current technology nuclear plant. That alternative fleet would also provide better reliability by diversifying the generation sources through smaller plants and avoid any radiation contamination risk.

The nuclear industry must clearly demonstrate that it can get past the many hurdles that led to the recent cancellation of two projects in the southeast U.S. Reviving nuclear power will require more than fantasies about what might be.

Dunning gets it wrong again on VCE


Valley Clean Energy Alliance (VCE) was in the Davis opinion columns this weekend again. First, Bob Dunning wrote another column in the Davis Enterprise that mischaracterizes the switch to VCE from PG&E as “mandated” and implies that local government didn’t trust Davis citizens to make the right choice. Then, David Greenwald wrote a column in the Davis Vanguard on how Dunning had ignored the authorization of the development and formation of VCE and is late to the game.

In both cases, the distinction between the choice to form VCE made by city councils and the Board of Supervisors after substantial study  is not distinguished from the choice that electricity ratepayers now have as to which entity will serve them. Previously, Yolo County ratepapers had no choice as to who should serve them–it took the formation of VCE to create that choice. If Dunning has a problem with that even offering that choice in the first place, then that’s a much more fundamental problem. But he is not being so transparent in his opposition, with is either disingenuous or ignorant.

I wrote the following email to Bob Dunning (I had an earlier letter to the editor already published in the Enterprise, that I also posted on this blog and the Davis Vanguard.)

You complain that somehow you’ve been “mandated” to sign up with Valley Clean Energy Authority. Yet you fail to ask the question “why was I mandated to sign up with PG&E all of those years?” Why does PG&E get a free pass from your scrutiny?

Instead now, you actually have a choice. We trust that you will make the right choice, whereas before you had NO choice. And you are not “mandated” to join VCE. You can act to switch to PG&E if you so choose. What has changed is the starting point of your choice. The default is no longer PG&E—it’s VCE. There’s nothing wrong with changing the default choice, but we have to start with a default since everyone wants to continue to receive electricity. (The other option is like they did with long distance service in the late 1980s with random assignment as the starting point, but that seems too much bother.)

 Send me your answers in your next column.

As to the Vanguard, I posted:

I think your column misses the fundamental point–contrary to everything that Dunning writes, we DO have a choice–it’s just that the starting point (default) isn’t what he wants. He prefers that the big corporations get the favored pole position.


Fixing college admissions


Harvard is being sued by a group of Asian-American students for discriminating against them through affirmative action admission standards. The Trump Administration is joining on their side. I have been troubled by the reliance on standardized tests and inflated GPAs as appropriate metrics for college admission. I propose two solutions to both of these problems:

  1. Colleges and universities should create mission statements about what the university wants to accomplish through educating students. These statements should go well beyond just saying “a well-rounded individual who is prepared for a career.” It should state that it wants a set of alumni that positively impact their communities in a number of dimensions (some not easily quantified) in a manner that improves social well being in a manner chosen by the university’s policy makers. This will require developing a consensus among those policy makers (e.g., the Board of Regents), but it will prompt a larger debate about the purpose of a college education that is badly needed right now.
  2. The colleges and universities should then conduct at least two statistical/econometric studies to determine the mix of traits that it wants in its student body to accomplish its objectives:
    • The first one would establish what preparation will lead to the most likely academic success in that college. This would completely eliminate the need for standardized tests. The key is that most colleges have an extensive set of data on the GPAs of their students, the high schools that they went to and their GPAs in high school (along with other academic data). The study (a regression)  would regress the college GPA on the high school GPA weighted by the high school (this adjusts for differences between high schools) plus a specific set of other academic / extracurricular data. This would be socio-economic blind. But most importantly, these results would NOT be the singular admission standard. It would be just a measure of likely academic success that could help identify how to deploy resources for those students once they enroll.
    • The second would evaluate how alumni impact their communities. This would rely on data about alumni on occupations, income, community activities, rate of return to certain communities based on socio-economic status, and community well-being. Alumni characteristics would include incoming socio-economics traits, study major, college GPA, extracurricular activities, and other factors thought to be important. This study (again, likely econometric) would measure the relative impact on community well-being (or other chosen objectives) of admitting students with certain characteristics and likelihood of certain majors and academic performance. For example, it might show admitting a student from Watts with a lower predicted GPA has a bigger community impact than admitting another from Beverly Hills with a higher GPA.
    • The desirable traits found in the second study would be used with the results of the first study to set admission policies in a fairly transparent way. A third study might assess what mix of student body traits is most likely to achieve the mission statement objectives. That could further help make the admission process more transparent.

Another finding of the obvious from academics…


This study published in the American Journal of Agricultural Economics seems to have a surprising finding, at least to academic economists, that farmers with riskier water supplies rely less on irrigation! What? If you’re uncertain about whether you will get water every year, you are less likely to count on that water to irrigate your crops? Who possibly would think that way?

One CEQA reform


Yet another housing development in Davis is being threatened with a lawsuit under CEQA. Almost every project in town has been sued by a small cadre of citizens, with Susan Rainier the most recent stalking horse. This group was first encouraged by a suit in the 1990s that was settled for more than $100,000 that went to two individuals. (Part of those funds went to start the “Flatlander.”) That pattern has been the modus operandi ever since.

The problem is that these individuals and organizations have rarely been meaningful participants in the planning and permitting process for these projects. A valuable CEQA reform would be to require that any litigant to participate in a meaningful way in the preparation of the EIR, and that the litigant include any document or discussion in the suit that is filed. The intent of litigation in CEQA was to act on a check on failing to address any concerns raised during the deliberative process–let’s make that the case.

The legitimate environmental concerns are to be addressed during the deliberative process. The potential litigants need to develop a record during the deliberative process that fully raises their concerns. A suit should be limited to the issues raised during that process, and the required evidence clearly specified during the process. The litigants can then more fully develop counter evidence in a suit if that is the final outcome.