Tag Archives: CAISO

Transmission: the hidden cost of generation

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The cost of transmission for new generation has become a more salient issue. The CAISO found that distributed generation (DG) had displaced $2.6 billion in transmission investment by 2018. The value of displacing transmission requirements can be determined from the utilities’ filings with FERC and the accounting for new power plant capacity. Using similar methodologies for calculating this cost in California and Kentucky, the incremental cost in both independent system operators (ISO) is $37 per megawatt-hour or 3.7 cents per kilowatt-hour in both areas. This added cost about doubles the cost of utility-scale renewables compared to distributed generation.

When solar rooftop displaces utility generation, particularly during peak load periods, it also displaces the associated transmission that interconnects the plant and transmits that power to the local grid. And because power plants compete with each other for space on the transmission grid, the reduction in bulk power generation opens up that grid to send power from other plants to other customers.

The incremental cost of new transmission is determined by the installation of new generation capacity as transmission delivers power to substations before it is then distributed to customers. This incremental cost represents the long-term value of displaced transmission. This amount should be used to calculate the net benefits for net energy metered (NEM) customers who avoid the need for additional transmission investment by providing local resources rather than remote bulk generation when setting rates for rooftop solar in the NEM tariff.

  • In California, transmission investment additions were collected from the FERC Form 1 filings for 2017 to 2020 for PG&E, SCE and SDG&E. The Wholesale Base Total Revenue Requirements submitted to FERC were collected for the three utilities for the same period. The average fixed charge rate for the Wholesale Base Total Revenue Requirements was 12.1% over that year. That fixed charge rate is applied to the average of the transmission additions to determine the average incremental revenue requirements for new transmission for the period. The plant capacity installed in California for 2017 to 2020 is calculated from the California Energy Commission’s “Annual Generation – Plant Unit”. (This metric is conservative because (1) it includes the entire state while CAISO serves only 80% of the state’s load and the three utilities serve a subset of that, and (2) the list of “new” plants includes a number of repowered natural gas plants at sites with already existing transmission. A more refined analysis would find an even higher incremental transmission cost.)

Based on this analysis, the appropriate marginal transmission cost is $171.17 per kilowatt-year. Applying the average CAISO load factor of 52%, the marginal cost equals $37.54 per megawatt-hour.

  • In Kentucky, Kentucky Power is owned by American Electric Power (AEP) which operates in the PJM ISO. PJM has a market in financial transmission rights (FTR) that values relieving the congestion on the grid in the short term. AEP files network service rates each year with PJM and FERC. The rate more than doubled over 2018 to 2021 at average annual increase of 26%.

Based on the addition of 22,907 megawatts of generation capacity in PJM over that period, the incremental cost of transmission was $196 per kilowatt-year or nearly four times the current AEP transmission rate. This equates to about $37 per megawatt-hour (or 3.7 cents per kilowatt-hour).

ERCOT has the peak period scarcity price too high

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The freeze and resulting rolling outages in Texas in February highlighted the unique structure of the power market there. Customers and businesses were left with huge bills that have little to do with actual generation expenses. This is a consequence of the attempt by Texas to fit into an arcane interpretation of an economic principle where generators should be able to recover their investments from sales in just a few hours of the year. Problem is that basic of accounting for those cashflows does not match the true value of the power in those hours.

The Electric Reliability Council of Texas (ERCOT) runs an unusual wholesale electricity market that supposedly relies solely on hourly energy prices to provide the incentives for incenting new generation investment. However, ERCOT is using the same type of administratively-set subsidies to create enough potential revenue to cover investment costs. Further, a closer examination reveals that this price adder is set too high relative to actual consumer value for peak load power. All of this leads to a conclusion relying solely on short-run hourly prices as a proxy for the market value that accrues to new entrants is a misplaced metric.

The total ERCOT market first relies on side payments to cover commitment costs (which creates barriers to entry but that’s a separate issue) and second, it transfers consumer value through to the Operating Reserve Demand Curve (ORDC) that uses a fixed value of lost load (VOLL) in an arbitrary manner to create “opportunity costs” (more on that definition at a later time) so the market can have sufficient scarcity rents. This second price adder is at the core of ERCOT’s incentive system–energy prices alone are insufficient to support new generation investment. Yet ERCOT has ignored basic economics and set this value too high based on both available alternatives to consumers and basic regional budget constraints.

I started with an estimate of the number of hours where prices need the ORDC to be at full VOLL of $9000/MWH to recover the annual revenue requirements of combustion turbine (CT) investment based on the parameters we collected for the California Energy Commission. It turns out to be about 20 to 30 hours per year. Even if the cost in Texas is 30% less, this is still more 15 hours annually, every single year or on average. (That has not been happening in Texas to date.) Note for other independent system operators (ISO) such as the California ISO (CAISO), the price cap is $1,000 to $2,000/MWH.

I then calculated the cost of a customer instead using a home generator to meet load during those hours assuming a life of 10 to 20 years on the generator. That cost should set a cap on the VOLL to residential customers as the opportunity cost for them. The average unit is about $200/kW and an expensive one is about $500/kW. That cost ranges from $3 to $5 per kWh or $3,000 to $5,000/MWH. (If storage becomes more prevalent, this cost will drop significantly.) And that’s for customers who care about periodic outages–most just ride out a distribution system outage of a few hours with no backup. (Of course if I experienced 20 hours a year of outage, I would get a generator too.) This calculation ignores the added value of using the generator for other distribution system outages created by events like a hurricane hitting every few years, as happens in Texas. That drives down this cost even further, making the $9,000/MWH ORDC adder appear even more distorted.

The second calculation I did was to look at the cost of an extended outage. I used the outages during Hurricane Harvey in 2017 as a useful benchmark event. Based on ERCOT and U.S. Energy Information Reports reports, it looks like 1.67 million customers were without power for 4.5 days. Using the Texas gross state product (GSP) of $1.9 trillion as reported by the St. Louis Federal Reserve Bank, I calculated the economic value lost over 4.5 days, assuming a 100% loss, at $1.5 billion. If we assume that the electricity outage is 100% responsible for that loss, the lost economic value per MWH is just under $5,000/MWH. This represents the budget constraint on willingness to pay to avoid an outage. In other words, the Texas economy can’t afford to pay $9,000/MWH.

The recent set of rolling blackouts in Texas provides another opportunity to update this budget constraint calculation in a different circumstance. This can be done by determining the reduction in electricity sales and the decrease in state gross product in the period.

Using two independent methods, I come up with an upper bound of $5,000/MWH, and likely much less. One commentator pointed out that ERCOT would not be able achieve a sufficient planning reserve level at this price, but that statement is based on the premises that short-run hourly prices reflect full market values and will deliver the “optimal” resource mix. Neither is true.

This type of hourly pricing overemphasizes peak load reliability value and undervalues other attributes such as sustainability and resilience. These prices do not reflect the full incremental cost of adding new resources that deliver additional benefits during non-peak periods such as green energy, nor the true opportunity cost that is exercised when a generator is interconnected rather than during later operations. Texas has overbuilt its fossil-fueled generation thanks to this paradigm. It needs an external market based on long-run incremental costs to achieve the necessary environmental goals.

The PCIA is heading California toward another energy crisis

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The California ISO Department of Market Monitoring notes in its comments to the CPUC on proposals to address resource adequacy shortages during last August’s rolling blackouts that the number of fixed price contracts are decreasing. In DMM’s opinion, this leaves California’s market exposed to the potential for greater market manipulation. The diminishing tolling agreements and longer term contracts DMM observes is the result of the structure of the power cost indifference adjustment (PCIA) or “exit fee” for departed community choice aggregation (CCA) and direct access (DA) customers. The IOUs are left shedding contracts as their loads fall.

The PCIA is pegged to short run market prices (even more so with the true up feature added in 2019.) The PCIA mechanism works as a price hedge against the short term market values for assets for CCAs and suppresses the incentives for long-term contracts. This discourages CCAs from signing long-term agreements with renewables.

The PCIA acts as an almost perfect hedge on the retail price for departed load customers because an increase in the CAISO and capacity market prices lead to a commensurate decrease in the PCIA, so the overall retail rate remains the same regardless of where the market moves. The IOUs are all so long on their resources, that market price variation has a relatively small impact on their overall rates.

This situation is almost identical to the relationship of the competition transition charge (CTC) implemented during restructuring starting in 1998. Again, energy service providers (ESPs) have little incentive to hedge their portfolios because the CTC was tied directly to the CAISO/PX prices, so the CTC moved inversely with market prices. Only when the CAISO prices exceeded the average cost of the IOUs’ portfolios did the high prices become a problem for ESPs and their customers.

As in 1998, the solution is to have a fixed, upfront exit fee paid by departing customers that is not tied to variations in future market prices. (Commissioner Jesse Knight’s proposal along this line was rejected by the other commissioners.) By doing so, load serving entities (LSEs) will be left to hedging their own portfolios on their own basis. That will lead to LSEs signing more long term agreements of various kinds.

The alternative of forcing CCAs and ESP to sign fixed price contracts under the current PCIA structure forces them to bear the risk burden of both departed and bundled customers, and the IOUs are able to pass through the risks of their long term agreements through the PCIA.

California would be well service by the DMM to point out this inherent structural problem. We should learn from our previous errors.

CAISO doesn’t quite grasp what led to rolling blackouts

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Steve Berberich, CEO of the California Independent System Operator, assessed for GTM  his views on the reasons for the rolling blackouts in the face of a record setting heat wave. He overlooked a key reason for the delay on capacity procurement (called “resource adequacy” or RA) and he demonstrated a lack of understanding of how renewables and batteries will integrate to provide peak capacity.

Berberich is unwilling to acknowledge that at least part of the RA procurement problem was created by CAISO’s unwillingness to step in as a residual buyer in the RA market, which then created resistance by the CCAs to putting the IOUs in that role. RA procurement was delayed at least a year due to CAISO’s reluctance. CAISO appears to be politically tone-deaf to the issues being raised by CCAs on system procurement.

He says that solar will have to be overbuilt to supply energy to batteries for peak load. But that is already the case with the NQC ELCC just a fraction of the installed solar and wind capacity. Renewable capacity above the ELCC is available to charge the batteries for later use. The only question then is how much energy is required from the batteries to support the peak load and is that coming from existing renewables fleet. The resource adequacy paradigm has changed (more akin to the old PNW hydro system) in which energy, not built capacity is becoming the constraint.

Should CCAs accept a slice of Diablo Canyon power?

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The northern California community choice aggregators (CCAs) are considering a offer from PG&E to allocate to each CCA a proportionate share of parts of its portfolio, including the Diablo Canyon nuclear generation station. Many CCA boards are hearing from anti-nuclear activists to deny this offer, both for moral reasons and the belief that such a rejection will somehow pressure PG&E financially. The first set of concern is beyond my professional expertise, but their reasoning on the economic and regulatory issues is incorrect.

  • CCAs buy a substantial portion of their generation (the majority for many of them) from the California Independent System Operator (CAISO) energy markets. PG&E schedules Diablo Canyon into those CAISO markets and under the current CAISO tariffs, nuclear generation is a “must take” resource that the CAISO can’t turn back. So the entire output of Diablo Canyon is scheduled into the CAISO market (without any bidding process), PG&E is paid the market clearing price (MCP) for that Diablo power, and the CCAs buy that mix of nuclear power at the MCP. There is no discretion for either the CAISO or the CCAs in taking excess power from Diablo. There is no “lifeline” for Diablo that the CCAs have any control over under current legal and regulatory parameters.
  • CCAs already pay for a proportionate share of Diablo Canyon equal to the CCAs share of overall load. That payment is broken into two parts (and maybe a third): 1) the purchase of energy from the CAISO at the MCP and 2) the stranded capital and operating costs above the MCP in the PCIA. (CCAs also may be paying for a share of the resource adequacy, but I haven’t thought through that one.) Thus, if the CCAs receive credit for the energy that they are already paying for, the energy portion essentially comes as “free”. In addition, because CCAs currently pay for the remaining share of Diablo costs, but get no energy credit for that in the PCIA calculation, then that credit is in the PCIA is also “free”. In addition, the CCAs gain credit for Diablo’s GHG-free generation (as recognized in the Air Resources Board GHG allowance program) as LSE’s for no extra cost, or for “free.” The bottom line is when the CCAs gain credit for products that they are already paying for, receipt of those products is for “free.”
  • Accepting this deal will not solve ALL of the CCAs problems, but that’s a false goal. That was never the intent. It does however give the CCAs a respite to get through the period until Diablo retires. One needs to recognize that this provides some of the needed relief.
  • Finally, there’s never any certainty over any large deal. Uncertainty should not freeze decision making. The uncertainty about the PCIA going forward is equally large and perhaps offsetting. The risks should be identified, discussed, considered and addressed to the extent possible. But that’s different than simply nixing the deal without addressing the other large risk. Naively believing that Diablo can be closed in short order (especially with the COVID crisis) is not a true risk management strategy.

From these points, we can come to these conclusions:

  1. Whether the CCAs accept or reject the nuclear offer has NO impact on PG&E’s revenue stream. The decisions that the CCAs face are entirely about whether the CCAs can lower their costs and gain some additional GHG reduction credits that they are already paying for (in other words, reduce their subsidies of bundled customers.) Nothing that the CCAs decide will affect the closure date of Diablo. If the CCAs reject the allocations, it will simply be business as usual to the full closures in 2025. Any other interpretation doesn’t reflect the current regulatory environment at the CPUC which are unlikely to change (and even that is unknown) until enough commissioners’ five-year terms roll over.
  2. The system can only be changed by legislative and regulatory action. That means that the CCAs must make the most prudent financial decisions within the current context rather than making a purely symbolic gesture that is financially adverse and will do nothing to change the BAU practice. A wise decision would consider what is the true impact of the action on
  3. Finally, early closure of Diablo will NOT remove the invested capital cost from PG&E’s ratebase, which is what drives the PCIA. After the plant is closed, activists will ALSO have to show that the INVESTMENT in the plant was imprudent and should not have been allowed. Given the long history on decisions and settlements in Diablo investment costs and the inclusion of recovery of Diablo costs in both AB1890 and AB1X at the beginning and end of the energy crisis, that is an impossible task. Only a constitutional amendment through the initiative process could possibly lead to such an action, and even that would have to survive a court challenge that probably would push past 2024.

I want to finish with what I think is a very important point that has been overlooked by the activists: The effort to close Diablo Canyon has won. Activists might not like the timeline of that victory, but it is a victory nevertheless that looked unachievable prior to 2016. It’s worthwhile considering whether the added effort for what will be for a variety of reasons little gain is an important question to answer.

Note that Diablo Canyon is already scheduled for closure in 2024 and 2025. A proceeding to either reopen A.16-08-006 or to open a new rulemaking or application would probably take close to a year, so the proceeding probably wouldn’t open until almost 2021. The actual proceeding would take up to a year, so now we’re to 2022 before an actual decision. PG&E would have to take up to a year to plan the closure at that point, which then takes us to 2023. So at best the plant closes a year earlier than currently scheduled. In addition, PG&E still receives the full payments for its investments and there’s likely no capital additions avoided by the early closure, so the cost savings would be minimal.

Nuclear vs. storage: which is in our future?

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Two articles with contrasting views of the future showed up in Utility Dive this week. The first was an opinion piece by an MIT professor referencing a study he coauthored comparing the costs of an electricity network where renewables supply more than 40% of generation compared to using advanced nuclear power. However, the report’s analysis relied on two key assumptions:

  1. Current battery storage costs are about $300/kW-hr and will remain static into the future.
  2. Current nuclear technology costs about $76 per MWh and advanced nuclear technology can achieve costs of $50 per MWh.

The second article immediately refuted the first assumption in the MIT study. A report from BloombergNEF found that average battery storage prices fell to $156/kW-hr in 2019, and projected further decreases to $100/kW-hr by 2024.

The reason that this price drop is so important is that, as the MIT study pointed out, renewables will be producing excess power at certain times and underproducing during other peak periods. MIT assumes that system operators will have to curtail renewable generation during low load periods and run gas plants to fill in at the peaks. (MIT pointed to California curtailing about 190 GWh in April. However, that added only 0.1% to the CAISO’s total generation cost.) But if storage is so cheap, along with inexpensive solar and wind, additional renewable capacity can be built to store power for the early evening peaks. This could enable us to free ourselves from having to plan for system peak periods and focus largely on energy production.

MIT’s second assumption is not validated by recent experience. As I posted earlier, the about to be completed Vogtle nuclear plant will cost ratepayers in Georgia and South Carolina about $100 per MWh–more than 30% more than the assumption used by MIT. PG&E withdrew its relicensing request for Diablo Canyon because the utility projected the cost to be $100 to $120 per MWh. Another recent study found nuclear costs worldwide exceeded $100/MWh and it takes an average of a decade finish a plant.

Another group at MIT issued a report earlier intended to revive interest in using nuclear power. I’m not sure of why MIT is so focused on this issue and continuing to rely on data and projections that are clearly outdated or wrong, but it does have one of the leading departments in nuclear science and engineering. It’s sad to see that such a prestigious institution is allowing its economic self interest to cloud its vision of the future.

What do you see in the future of relying on renewables? Is it economically feasible to build excess renewable capacity that can supply enough storage to run the system the rest of the day? How would the costs of this system compare to nuclear power at actual current costs? Will advanced nuclear power drop costs by 50%? Let us know your thoughts and add any useful references.

PG&E apologizes, yet again

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(Image: ABC 7 News)

I listened to PG&E’s CEO Bill Johnson and his staff apologize for its mishandling of the public safety power shutoffs (PSPS) that affected over 700,000 “customers” (what other industry calls meters “customers”?) yesterday. And as I listened, I thought of the many times that PG&E has fumbled (or even acted maliciously) over the years. Here’s my partial list (and I’m leaving out the faux pas that I’ve experienced in regulatory proceedings):

  • Failing to turn off power locally in 2017 and 2018 under hazardous weather conditions, which led to the Wine Country and Camp fires.
  • Failing to install distribution shut off equipment that was installed by San Diego Gas & Electric and Southern California Edison after the 2007 wildfires in Southern  California.
  • Signing too many power purchase agreements with renewables in the 2009 to 2014 period that were for too long of terms (e.g., 20 years instead of 10 years). PG&E is unable to take advantage of the dramatic cost decreases created by California’s bold investments. For a comparison, PG&E’s renewable portfolio costs about 20% more than SCE’s. (I am one of a few that has access to the confidential portfolio data for both utilities.)
  • Failing to act on the opportunity to sell part of its overstuffed renewable portfolio to the CCAs that emerged from 2010 to 2016. Those sales could have benefited everyone by decreasing PG&E’s obligations and providing the CCAs with existing firm resources. That opportunity has now largely passed.
  • The gas pipeline explosion in San Bruno in 2010 caused by PG&E’s failure to keep proper records for decades. PG&E was convicted of a felony for its negligence.
  • Overinvesting in obsolete distribution infrastructure after 2009 by failing to recognize that electricity demand had flattened and that customers were switching en masse to solar rooftops. (I repeatedly filed testimony starting in 2010 pointing out this error.)
  • Deploying an Advanced Meter Infrastructure (AMI) system starting in 2004 using SmartMeters that claimed that it would provide much more control of PG&E’s distribution system, and deliver positive benefits to ratepayers. Savings have largely failed to materialize, and PG&E’s inability to use its AMI to more narrowly target its PSPS illustrates how AMI has failed to deliver.
  • Acquiring and building three unneeded natural gas plants starting in 2006. Several merchant-owned plants constructed in the early 2000s are already on the verge of retiring because of the flattening in demand.
  • Failing to act in May 2000 to end the “competitive transition” period of California’s restructuring by agreeing to the market valuation of its hydropower system.
  • If PG&E had ended the transition period, it would have been immediately free to sign longer term contracts with merchant generators, thereby taking away the incentive for those generators to manipulate the market. The subsequent energy crisis most likely would have not occurred, or been much more isolated to Southern California.
  • PG&E’s CEO in 1998 made a speech to the shareholders stating that it was PG&E’s intent to extend the transition period as far as possible, to March 2001 at least. (We cited this speech from a transcript in the 1999 GRC case.)
  • Offering rebuttal in the 1999 GRC that instead confirmed the ORA’s analysis that the optimal size of a utility is closer to 500,000 customers rather than 4 million plus. Commissioner Bilas wrote a draft decision confirming this finding, but restructuring derailed the vote on the case.
  • Being caught by the CPUC in diverting $495 million from maintenance spending to shareholders from 1992 to 1997. PG&E was fined $29 million.
  • Forcing the CPUC in 1996 to adopt the “competitive transition charge” which was tied to the fluctuating CAISO day-ahead market price instead of using Commissioner Knight’s up front pay out for stranded assets. The CTC led to the “transition period” which facilitated the ability of merchant generators to manipulate the market price.
  • Two settlement agreements allow PG&E to fully recover its costs in Diablo Canyon by January 1, 1998 based on its authorized rate of return from 1986 to 1998, but also allows it to put into ratebase about half of its “remaining” construction costs as a prelude to restructuring.
  • Getting caught in 1990 telling FERC that PG&E was short resources and needed to build more, while telling the CPUC that it had a long term surplus and that it needed to curtail its payments to third-party qualifying facilities (QF) generators.
  • In the early 1980s, failing to set up a rationale process for signing QF contracts that limited the addition of these resources. In addition, PG&E missed an important pricing calculation mistake in the capacity payment term that led to a double payment to QFs.
  • In the 1970s, making many construction management mistakes when building the Diablo Canyon nuclear power plant, including reversing the blueprints, that led to the costs rising from $315 million to over $5 billion. (And Diablo Canyon in 3 of the last 5 years has operated at a loss and should not have been generating for several months each of those years.)
  • In the 1960s, signing an agreement with Sacramento Municipal Utility District (SMUD) to finance the construction of the Rancho Seco nuclear plant that essentially gave SMUD free energy when Rancho Seco wasn’t generating. The result was the mismanagement of the plant, which was so damaged that it was closed in 1989 (in part as a result of analysis conducted by the consulting team that I was on.)

The other two California IOUs are guilty of some of these same errors, and SMUD and Los Angeles Department of Water and Power (LADWP) also do not have a clean bill of health, but the quantities and magnitudes to don’t match those of PG&E.

The Business Roundtable takes the wrong lesson from California’s energy costs

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The California Business Roundtable authored an article in the San Francisco Chronicle claiming that the we only need to look to California’s energy prices to see what would happen with the “Green New Deal” proposed by the Congressional Democrats.

That article has several errors and is misleading in others aspects. First, California’s electricity rates are high because of the renewable contracts signed nearly a decade ago when renewables were just evolving and much higher cost. California’s investment was part of the reason that solar and wind costs are now lower than existing coals plants (new study shows 75% of coal plants are uneconomic) and competitive with natural gas. Batteries that increase renewable operations have almost become cost effective. It also claims that reliability has “gone down” when in fact we still have a large reserve margin. The California Independent System Operator in fact found a 23% reserve margin when the target is only 17%. We also have the ability to install batteries quickly to solve that issue. PG&E is installing over 500 MW of batteries right now to replace a large natural gas plant.

For the rest of the U.S., consumers will benefit from these lower costs today. Californians have paid too much for their power to date, due to mismanagement by PG&E and the other utilities, but elsewhere will be able to avoid these foibles.

(Graphic: BNEF)

CAISO: Renewables served 42% of California demand on May 16, setting record | Utility Dive

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During the 2 p.m. hour, renewables served more than 70% of power demand, setting another record in California.

Source: CAISO: Renewables served 42% of California demand on May 16, setting record | Utility Dive

Repost: CAISO notches record, serving 56.7% of demand with renewable energy in one day | Utility Dive

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Solar and wind power combined also hit a peak on the same day by serving 49.2% of demand.

Source: CAISO notches record, serving 56.7% of demand with renewable energy in one day | Utility Dive