Tag Archives: California

Commentary on CPUC Rate Design Workshop

cartoon

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.

Advertisements

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.

Lomborg has it wrong about California’s cap and trade program. 

Bjorn Lomborg, a Danish political scientist who has pushed for focusing spending on other pressing world needs over reducing climate change risk, has criticized the extension of California’s cap and trade program in the LA Times. I found two serious flaws in Lomborg’s analysis that undermine his conclusions.

The study that Lomberg cites about the electricity market impacts has not been reproduced since such extensive “contract reshuffling” can’t occur in the Western Electricity Coordinating Council (WECC) region or in the CAISO market. That’s just a simplistic modeling exercise not tied to reality. The fact is that thousands of megawatts of coal plants are retiring across the WECC at least in part in response to the cap & trade and renewables portfolio standards (RPS) adopted by California.

And then Lomberg writes “A smarter approach to climate policy — and one befitting California’s role as one of the most innovative states in the country — would be to focus on making green energy cheaper. ” Has Lomberg noticed that new solar and wind installations are now cheaper than new fossil-fueled plants? Contracts are being signed for less than 5 cents per kilowatt-hour–PG&E’s average cost for existing generation is close to 9 cents.

It’s as though Lomberg hasn’t updated his understanding of the energy industry since 2009 when the Copenhagen climate accord was signed.

Analyses of California’s extended cap and trade program

california

I believe that California’s passage of the extended cap and trade program was a generally good compromise. Most importantly, it decoupled the cap and trade market from separate legislation to regulate local emission impacts. As I wrote earlier, earlier proposals failed on this aspect.

Here’s the two best analyses I’ve seen so far, one legal and the other economic (by a former Michigan classmate), of the legislation.

State supreme court upholds AB 32, consistent with state-defined property rights

fig2

The California State Supreme Court refused to rehear a state appellate court decision that upheld the validity of the cap and trade program (CATP) established in Assembly Bill 32 (2006). Those challenging the program claimed that (1) the program required firms to acquire allowances to operate and (2) that the auction receipts were budgeted into state programs like other tax revenues. However, the Court’s decision was a victory for those who believe that stronger property rights can lead to an improved environment.

The AB 32 CATP defined the property rights for individual firms and for the public in allowed GHG emissions into the atmosphere.  CARB also allocated allowances for free to these firms and set rates of declining annual emission totals (with some upward adjustments to accommodate interstate and international competitiveness). This is akin to delineating the acreage that a property owner has, and then setting out a rate at which the property owner must dedicate a portion to public use, while still allowing the owner to continue to use that land. The U.S. Supreme Court just upheld the ability of state governments to regulate land use in this manner. The CATP essentially allows an owner to continue to use the land in same manner by acquiring usage rates from other owners who may find it more lucrative to sell their allowances rather than use them. Under AB 32, the state auctions some of those allowances to make for a liquid market, while other allowances are traded bilaterally amongst firms. The bottom line is that CATP established property rights in GHG emissions, just as California established water property rights in 1914.

If the CATP had been declared to be another tax, then any disbursement of government property that generated revenues, e.g., sale of excess office space or forest land, could also be considered a “tax” subject to a two-thirds vote approval by the State Legislature under the state constitution. I doubt that the plaintiffs in this case (led by the Chamber of Commerce) intended that sale of state property would require a two-thirds supermajority vote.

Another reason SB 775 is a bad idea: Virginia to establish cap-and-trade program in push to regulate carbon emissions | Utility Dive

California’s SB 775 would prohibit interaction with other states’ cap and trade programs. The best alternative to a federal program is a network of state markets.

“A cap-and-trade program in Virginia would be the third in the U.S., and buck direction from the White House to pull back on carbon regulation.”

Source: Virginia to establish cap-and-trade program in push to regulate carbon emissions | Utility Dive

Opening up California’s utility procurement process could lead to lower power prices

auction

California passed AB 57 in 2002 to make the power procurement process for electric utilities confidential (as well as subject only to upfront review rather than ongoing prudence standards). The result has been overly high prices locked in for decades.  A new study on the relative gains to landowners who sell the development rights for oil and gas development in Texas shows that using auctions creates more competition among multiple bidders than bilateral negotiations. As a result, landowners get higher prices for their development rights through an auction. The corollary is that California’s electric utilities probably could lower their power purchase costs by moving to public auctions instead. Yet another reason to repeal AB 57.