Tag Archives: building decarbonization

What “Electrify Everything” has wrong about “reduce, reuse, recycle”

Saul Griffith has written a book that highlights the role of electrification in achieving greenhouse gas emission reductions, and I agree with his basic premise. But he misses important aspects about two points. First, the need to reduce, reuse and recycle goes well beyond just energy consumption. And second, we have the ability to meet most if not all of our energy needs with the lowest impact renewable sources.

Reduce, reuse and recycle is not just about energy–it’s also about reducing consumption of natural resources such as minerals and biomass, as well as petroleum and methane used for plastics, and pollution caused by that consumption. In many situations, energy savings are only a byproduct. Even so, almost always the cheapest way to meet an energy need is to first reduce its use. That’s what energy efficiency is about. So we don’t want to just tell consumers to continue along their merry way, just switch it up with electricity. A quarter to a third our global GHG emissions are from resource consumption, not energy use.

In meeting our energy needs, we can largely rely on solar and wind supplemented with biofuels. Griffith asserts that the U.S. would need 2% of its land mass to supply the needed electricity, but his accounting makes three important errors. First, placing renewables doesn’t eliminate other uses of that land, particularly for wind. Acreage devoted to wind in particular can be used also for different types of farming and even open space. In comparison, fossil-fuel and nuclear plants completely displace any other land use. Turbine technology is evolving to limit avian mortality (and even then its tall buildings and household cats that cause most bird deaths). Second most of the solar supply can be met on rooftops and covering parking lots. These locations are cost effective compared to grid scale sources once we account for transmission costs. And third, our energy storage is literally driving down the road–in our new electric vehicles. A 100% EV fleet in California will have enough storage to meet 30 times the current peak load. A car owner will be able to devote less than 5% of their battery capacity to meet their home energy needs. All of this means that the real footprint can be much less than 1%.

Nuclear power has never lived up to its promise and is expensive compared to other low-emission options. While the direct costs of current-technology nuclear power is more than 12 cents a kilowatt-hour when adding transmission, grid-scale renewables are less than half of that, and distributed energy resources are at least comparable with almost no land-use footprint and able to provide better reliability and resilience. In addition, the potential of catastrophic events at nuclear plants adds another 1 to 3 cents per kilowatt-hour. Small modular reactors (SMR) have been promoted as a game changer, but we have been waiting for two decades. Nuclear or green hydrogen may emerge as economically-viable options, but we shouldn’t base our plans on that.

Proposing a Clean Financing Decarbonization Incentive Rate

by Steven J. Moss and Richard J. McCann, M.Cubed

A potentially key barrier to decarbonizing California’s economy is escalating electricity costs.[1] To address this challenge, the Local Government Sustainable Energy Coalition, in collaboration with Santa Barbara Clean Energy, proposes to create a decarbonization incentive rate, which would enable customers who switch heating, ventilation and air conditioning (HVAC) or other appliances from natural gas, fossil methane, or propane to electricity to pay a discounted rate on the incremental electricity consumed.[2] The rate could also be offered to customers purchasing electric vehicles (EVs).

California has adopted electricity rate discounts previously to incentivize beneficial choices, such as retaining and expanding businesses in-state,[3] and converting agricultural pump engines from diesel to electricity to improve Central Valley air quality.[4]

  • Economic development rates (EDR) offer a reduction to enterprises that are considering leaving, moving to or expanding in the state.  The rate floor is calculated as the marginal cost of service for distribution and generation plus non-bypassable charges (NBC). For Southern California Edison, the current standard EDR discount is 12%; 30% in designated enhanced zones.[5]
  • AG-ICE tariff, offered from 2006 to 2014, provided a discounted line extension cost and limited the associated rate escalation to 1.5% a year for 10 years to match forecasted diesel fuel prices.[6] The program led to the conversion of 2,000 pump engines in 2006-2007 with commensurate improvements in regional air quality and greenhouse gas (GHG) emission reductions.[7]

The decarbonization incentive rate (DIR) would use the same principles as the EDR tariff. Most importantly, load created by converting from fossil fuels is new load that has only been recently—if at all–included in electricity resource and grid planning. None of this load should incur legacy costs for past generation investments or procurement nor for past distribution costs. Most significantly, this principle means that these new loads would be exempt from the power cost indifference adjustment (PCIA) stranded asset charge to recover legacy generation costs.

The California Public Utility Commission (CPUC) also ruled in 2007 that NBCs such as for public purpose programs, CARE discount funding, Department of Water Resources Bonds, and nuclear decommissioning, must be recovered in full in discounted tariffs such as the EDR rate. This proposal follows that direction and include these charges, except the PCIA as discussed above.

Costs for incremental service are best represented by the marginal costs developed by the utilities and other parties either in their General Rate Case (GRC) Phase II cases or in the CPUC’s Avoided Cost Calculator. Since the EDR is developed using analysis from the GRC, the proposed DIR is illustrated here using SCE’s 2021 GRC Phase II information as a preliminary estimate of what such a rate might look like. A more detailed analysis likely will arrive at a somewhat different set of rates, but the relationships should be similar.

For SCE, the current average delivery rate that includes distribution, transmission and NBCs is 9.03 cents per kilowatt-hour (kWh). The average for residential customers is 12.58 cents. The system-wide marginal cost for distribution is 4.57 cents per kilowatt-hour;[8] 6.82 cents per kWh for residential customers. Including transmission and NBCs, the system average rate component would be 7.02 cents per kWh, or 22% less. The residential component would be 8.41 cents or 33% less.[9]

The generation component similarly would be discounted. SCE’s average bundled generation rate is 8.59 cents per kWh and 9.87 cents for residential customers. The rates derived using marginal costs is 5.93 cents for the system average and 6.81 cent for residential, or 31% less. For CCA customers, the PCIA would be waived on the incremental portion of the load. Each CCA would calculate its marginal generation cost as it sees fit.

For bundled customers, the average rate would go from 17.62 cents per kWh to 12.95 cents, or 26.5% less. Residential rates would decrease from 22.44 cents to 15.22 cents, or 32.2% less.

Incremental loads eligible for the discounted decarb rate would be calculated based on projected energy use for the appropriate application.  For appliances and HVAC systems, Southern California Gas offers line extension allowances for installing gas services based on appliance-specific estimated consumption (e.g., water heating, cooking, space conditioning).[10] Data employed for those calculations could be converted to equivalent electricity use, with an incremental use credit on a ratepayer’s bill. An alternative approach to determine incremental electricity use would be to rely on the California Energy Commission’s Title 24 building efficiency and Title 20 appliance standard assumptions, adjusted by climate zone.[11]

For EVs, the credit would be based on the average annual vehicle miles traveled in a designated region (e.g., county, city or zip code) as calculated by the California Air Resources Board for use in its EMFAC air quality model or from the Bureau of Automotive Repair (BAR) Smog Check odometer records, and the average fleet fuel consumption converted to electricity. For a car traveling 12,000 miles per year that would equate to 4,150 kWh or 345 kWh per month.


[1] CPUC, “Affordability Phase 3 En Banc,” https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/affordability, February 28-March 1, 2022.

[2] Remaining electricity use after accounting for incremental consumption would be charged at the current otherwise applicable tariff (OAT).

[3] California Public Utilities Commission, Decision 96-08-025. Subsequent decisions have renewed and modified the economic development rate (EDR) for the utilities individually and collectively.

[4] D.05-06-016, creating the AG-ICE tariff for Pacific Gas & Electric and Southern California Edison.

[5] SCE, Schedules EDR-E, EDR-A and EDR-R.

[6] PG&E, Schedule AG-ICE—Agricultural Internal Combustion Engine Conversion Incentive Rate.

[7] EDR and AG-ICE were approved by the Commission in separate utility applications. The mobile home park utility system conversion program was first initiated by a Western Mobile Home Association petition by and then converted into a rulemaking, with significant revenue requirement implications. 

[8] Excluding transmission and NBCs.

[9] Tiered rates pose a significant barrier to electrification and would cause the effective discount to be greater than estimated herein.  The estimates above were based on measuring against the average electricity rate but added demand would be charged at the much higher Tier 2 rate. The decarb allowance could be introduced at a new Tier 0 below the current Tier 1.

[10] SCG, Rule No. 20 Gas Main Extensions, https://tariff.socalgas.com/regulatory/tariffs/tm2/pdf/20.pdf, retrieved March 2022.

[11] See https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards;
https://www.energy.ca.gov/rules-and-regulations/building-energy-efficiency/manufacturer-certification-building-equipment;https://www.energy.ca.gov/rules-and-regulations/appliance-efficiency-regulations-title-20

What is the real threat to electrification? Not solar rooftops

The real threat to electrification are the rapidly escalating costs in the distribution system, not some anomaly in rate design related to net energy metering. As I have written here several times, rooftop solar if anything has saved ratepayers money so far, just as energy efficiency has done so. PG&E’s 2023 GRC is asking for a 66% increase in distribution rates by 2026 and average rates will approach 40 cents/kWh. We need to be asking why are these increases happening and what can we do to make electricity affordable for everyone.

Perhaps most importantly, the premise that there’s a “least cost” choice put forward by economists at the Energy Institute at Haas among others implies that there’s some centralized social welfare function. This is a mythological construct created for the convenience of economists (of which I’m one) to point to an “efficient” solution. Other societal objectives beyond economic efficiency include equitably allocating cost responsibility based on economic means, managing and sharing risks under uncertainty, and limiting political power that comes from economic assets. Efficiency itself is limited in what it tells us due to the multitude of market imperfections. The “theory of the second best” states that in an economic sector with uncorrected market failures, actions to correct market failures in another related sector with the intent of increasing economic efficiency may actually decrease overall economic efficiency. In the utility world for example, shareholders are protected from financial losses so revenue shortfalls are allocated to customers even as their demands fall. This blunts the risk incentive that is central to economic efficiency. Claiming that adding a fixed charge will “improve” efficiency has little basis without a complete, fundamental assessment of the sector’s market functionality.

The real actors here are individual customers who are making individual decisions in our current economic resource allocation system, and not a central entity dictating choices to each of us. Different customers have different preferences in what they value and what they fear. Rooftop installations have been driven to a large extent by a dread of utility mismanagement that makes expectations about future rates much more uncertain.

The single most important trait of a market economy is the discipline imposed by appropriately assigning risk burden to the decision make and not pricing design. The latter is the tail wagging the dog. Market distortions are universally caused by separating consequences from decisions. And right now the only ability customers have to exercise control over their electricity bills is to somehow exit the system. If we take away that means of discipline we will never be able to control electricity rates in a way that will lead to effective electrification.

Are fixed charges the solution to the solar rooftop dilemma?

A recent post at the Energy Institute at Haas proposed that all residential ratepayers should pay the “solar tax” in the recently withdrawn proposed decision from the California Public Utilities Commission through a connection fee. I agree that charging residential a connection charge is a reasonable solution. (All commercial and agricultural customers in California already pay such a charge.) The more important question though is what that connection fee should be?

Much less of the distribution costs are “fixed” than many proponents understand–we can see an example of the ability to avoid large undergrounding costs by installing microgrids as an example. Southern California Edison has repeatedly asked for a largely fixed “grid charge” for the last dozen years and the intervening ratepayer groups have shown that SCE’s estimate is much too high. A service connection costs about $10-$15/month, not more than $50 per month. So what might be the other elements of a fixed monthly charge rather than collecting these revenues through a volumetric rate as is done today?

A strong economic argument can be made that if the utility is collecting a fixed charge for upstream T&D capacity, then a customer should be able to trade that capacity that they have paid for with other customers. In the face of transaction costs, that market would devolve down to the per kWh price managed by the utility acting as a dealer–just what we have today.

Other candidates abound. How to recover stranded costs really requires a conversation about how much of those costs shareholders should shoulder. Income distributional public purpose costs should be collected from taxes, not rates. Energy efficiency is a resource that should be charged in the generation component, not distribution, and should be treated like other generation resources in cost recovery. The problem is that decoupling which was used to encourage energy efficiency investment has become a backdoor way to recover stranded costs without any conversation about whether that is appropriate–rates go up as demand decreases with little reduction in revenue requirements. So what the connection charge should be becomes quite complex.

AB1139 would undermine California’s efforts on climate change

Assembly Bill 1139 is offered as a supposed solution to unaffordable electricity rates for Californians. Unfortunately, the bill would undermine the state’s efforts to reduce greenhouse gas emissions by crippling several key initiatives that rely on wider deployment of rooftop solar and other distributed energy resources.

  • It will make complying with the Title 24 building code requiring solar panel on new houses prohibitively expensive. The new code pushes new houses to net zero electricity usage. AB 1139 would create a conflict with existing state laws and regulations.
  • The state’s initiative to increase housing and improve affordability will be dealt a blow if new homeowners have to pay for panels that won’t save them money.
  • It will make transportation electrification and the Governor’s executive order aiming for 100% new EVs by 2035 much more expensive because it will make it much less economic to use EVs for grid charging and will reduce the amount of direct solar panel charging.
  • Rooftop solar was installed as a long-term resource based on a contractual commitment by the utilities to maintain pricing terms for at least the life of the panels. Undermining that investment will undermine the incentive for consumers to participate in any state-directed conservation program to reduce energy or water use.

If the State Legislature wants to reduce ratepayer costs by revising contractual agreements, the more direct solution is to direct renegotiation of RPS PPAs. For PG&E, these contracts represent more than $1 billion a year in excess costs, which dwarfs any of the actual, if any, subsidies to NEM customers. The fact is that solar rooftops displaced the very expensive renewables that the IOUs signed, and probably led to a cancellation of auctions around 2015 that would have just further encumbered us.

The bill would force net energy metered (NEM) customers to pay twice for their power, once for the solar panels and again for the poor portfolio management decisions by the utilities. The utilities claim that $3 billion is being transferred from customers without solar to NEM customers. In SDG&E’s service territory, the claim is that the subsidy costs other ratepayers $230 per year, which translates to $1,438 per year for each NEM customer. But based on an average usage of 500 kWh per month, that implies each NEM customer is receiving a subsidy of $0.24/kWh compared to an average rate of $0.27 per kWh. In simple terms, SDG&E is claiming that rooftop solar saves almost nothing in avoided energy purchases and system investment. This contrasts with the presumption that energy efficiency improvements save utilities in avoided energy purchases and system investments. The math only works if one agrees with the utilities’ premise that they are entitled to sell power to serve an entire customer’s demand–in other words, solar rooftops shouldn’t exist.

Finally, this initiative would squash a key motivator that has driven enthusiasm in the public for growing environmental awareness. The message from the state would be that we can only rely on corporate America to solve our climate problems and that we can no longer take individual responsibility. That may be the biggest threat to achieving our climate management goals.