Tag Archives: distribution planning

Public takeover of PG&E isn’t going to solve every problem

This article in the Los Angeles Times about what a public takeover of PG&E appears to take on uses the premise that such a step would lead to lower costs, more efficiencies and reduced wildfire risks. These expectations have never been realistic, and shouldn’t be the motivation for such an action. Instead, a public takeover would offer these benefits and opportunities:

  • While the direct costs of constructing and repairing the grid would likely be about the same (and PG&E has some of the highest labor costs around), the cost to borrow and invest the needed funds would be as much as 30% less. That’s because PG&E weighted average cost of capital (debt and shareholder equity) is around 8% per annum while muncipal debt is 5% or less.
  • Ratepayers are already repaying shareholders and creditors for their investments in the utility system. Buying PG&E’s system would simply be replacing those payments with payments to creditors that hold public bonds. Similar to the cost of fixing the grid, this purchase should reduce the annual cost to repay that debt by 30%.
  • And along these lines, utility shareholders have borne little of the costs from these types of risks. Shareholders supposedly get a premium on their investment returns for these “risks” but when asked for examples of large scale disallowances, none of the utilities could provide significant examples. If ratepayers are already bearing all of those risks, then they should get all of the investment benefits as well.
  • Direct public oversight will eliminate a layer of regulation that PG&E has used to impede effective oversight and deflect responsibility. To some extent regulation by the California Public Utilities Commission has been like pushing on a string, with PG&E doing what it wants by “interpreting” CPUC decisions. The result has been a series of missteps by the utility over many decades.
  • A new utility structure may provide an opportunity to renegotiate a number of overly lucrative renewable power purchase agreements that PG&E signed between 2010 and 2015. PG&E failed to properly manage the risk profile of its portfolio because under state law it could pass through all costs of those PPAs once approved by the CPUC. PG&E’s shareholders bore no risk, so why consider that risk? There are several possible options to addressing this issue, but PG&E has little incentive to act.
  • A publicly-owned utility can work more closely with local governments to facilitate the evolution of the energy system to meet climate change challenges. As a private entity with restrictions on how it can participate in customer-side energy management, PG&E cannot work hand-in-glove with cities and counties on building and transportation transformation. PG&E right now has strong incentives to prevent further defections away from its grid; public utilities are more likely to accept these defections with the possibility that the stranded asset costs will be socialized.

The risks of wildfire damages and liabilities are unlikely to change substantially (except if the last point accelerates distributed energy resource investment). But the other benefits and opportunities are likely to make these costs lower.

Microgrids could cost 10% of undergrounding PG&E’s wires

One proposed solution to reducing wildfire risk is for PG&E to put its grid underground. There are a number of problems with undergrounding including increased maintenance costs, seismic and flooding risks, and problems with excessive heat (including exploding underground vaults). But ignoring those issues, the costs could be exorbitant-greater than anyone has really considered. An alternative is shifting rural service to microgrids. A high-level estimate shows that using microgrids instead could cost less than 10% of undergrounding the lines in regions at risk. The CPUC is considering a policy shift to promote this type of solution and has new rulemaking on promoting microgrids.

We can put this in context by estimating costs from PG&E’s data provided in its 2020 General Rate Case, and comparing that to its total revenue requirements. That will give us an estimate of the rate increase needed to fund this effort.

PG&E has about 107,000 miles of distribution voltage wires and 18,500 in transmission lines. PG&E listed 25,000 miles of distribution lines being in wildfire risk zones. The the risk is proportionate for transmission this is another 4,300 miles. PG&E has estimated that it would cost $3 million per mile to underground (and ignoring the higher maintenance and replacement costs). And undergrounding transmission can cost as much as $80 million per mile. Using estimates provided to the CAISO and picking the midpoint cost adder of four to ten times for undergrounding, we can estimate $25 million per mile for transmission is reasonable. Based on these estimates it would cost $75 billion to underground distribution and $108 billion for transmission, for a total cost of $183 billion. Using PG&E’s current cost of capital, that translates into annual revenue requirement of $9.1 billion.

PG&E’s overall annual revenue requirement are currently about $14 billion and PG&E has asked for increases that could add another $3 billion. Adding $9.1 billion would add two-thirds (~67%) to PG&E’s overall rates that include both distribution and generation. It would double distribution rates.

This begs two questions:

  1. Is this worth doing to protect properties in the affected urban-wildlands interface (UWI)?
  2. Is there a less expensive option that can achieve the same objective?

On the first question, if we look the assessed property value in the 15 counties most likely to be at risk (which includes substantial amounts of land outside the UWI), the total assessed value is $462 billion. In other words, we would be spending 16% of the value of the property being protected. The annual revenue required would increase property taxed by over 250%, going from 0.77% to 2.0%.

Which turns us to the second question. If we assume that the load share is proportionate to the share of lines at risk, PG&E serves about 18,500 GWh in those areas. The equivalent cost per unit for undergrounding would be $480 per MWh.

The average cost for a microgrid in California based on a 2018 CEC study is $3.5 million per megawatt. That translates to $60 per MWh for a typical load factor. In other words a microgrid could cost one-eighth of undergrounding. The total equivalent cost compared to the undergrounding scenario would be $13 billion. This translates to an 8% increase in PG&E rates.

To what extent should we pursue undergrounding lines versus shifting to microgrid alternatives in the WUI areas? Should we encourage energy independence for these customers if they are on microgrids? How should we share these costs–should locals pay or should they be spread over the entire customer base? Who should own these microgrids: PG&E or CCAs or a local government?





Commentary on CPUC Rate Design Workshop


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.

Repost: Lessons From 40 Years of Electricity Market Transformation: Storage Is Coming Faster Than You Think | Greentech Media

Five useful insights into where the electricity industry is headed.

Source: Lessons From 40 Years of Electricity Market Transformation: Storage Is Coming Faster Than You Think | Greentech Media

Study shows investment and reliability are disconnected

Lawrence Berkeley National Laboratory released a study on how utility investment in transmission and distribution compares to changes in reliability. LBNL found that outages are increasing in number and duration nationally, and that levels of investment are not well correlated with improved reliability.

We testified on behalf of the Agricultural Energy Consumers Association in both the SCE and PG&E General Rate Cases about how distribution investment is not justified by the available data. Both utilities asked for $2 billion to meet “growth” yet both have seen falling demand since 2007. PG&E invested $360 million in its Cornerstone Improvement program, but a good question is, what is the cost-effectiveness of that improved reliability? Perhaps the new distribution resource planning exercise will redirect investment in a more rationale way.

Is the Future of Electricity Generation Really Distributed?

Severin Borenstein at UC Energy Institute blogs about the push for distributed solar, perhaps at the expense of other cost-effective renewables development. My somewhat contrary comment on that is here: https://energyathaas.wordpress.com/2015/05/04/is-the-future-of-electricity-generation-really-distributed/#comment-8092