Tag Archives: energy economics

Do small modular reactors (SMR) hold real promise?

The economic analyses of the projected costs for small modular reactors (SMRs) appear to rely on two important assumptions: 1) that the plants will run at capacity factors of current nuclear plants (i.e., 70%-90%+) and 2) that enough will be built quickly enough to gain from “learning by doing” on scale as has occurred with solar, wind and battery technologies. The problem with these assumptions is that they require that SMRs crowd out other renewables with little impact on gas-fired generation.

To achieve low costs in nuclear power requires high capacity factors, that is the total electricity output relative to potential output. The Breakthrough Institute study, for example, assumes a capacity factor greater than 80% for SMRs. The problem is that the typical system load factor, that is the average load divided by the peak load, ranges from 50% to 60%. A generation capacity factor of 80% means that the plant is producing 20% more electricity than the system needs. It also means that other generation sources such as solar and wind will be pushed aside by this amount in the grid. Because the SMRs cannot ramp up and down to the same degree as load swings, not only daily but also seasonally, the system will still need load following fossil-fuel plants or storage. It is just the flip side of filling in for the intermittency of renewables.

To truly operate within the generation system in a manner that directly displaces fossil fuels, an SMR will have to operate at a 60% capacity factor or less. Accommodating renewables will lower that capacity factor further. Decreasing the capacity factor from 80% to 60% will increase the cost of an SMR by a third. This would increase the projected cost in the Breakthrough Institute report for 2050 from $41 per megawatt-hour to $55 per megawatt-hour. Renewables with storage are already beating this cost in 2022 and we don’t need to wait 30 years.

And the Breakthrough Institute study relies questionable assumptions about learning by doing in the industry. First, it assumes that conventional nuclear will experience a 5% learning benefit (i.e., costs will drop 5% for each doubling of capacity). In fact, the industry shows a negative learning rate--costs per kilowatt have been rising as more capacity is built. It is not clear how the SMR industry will reverse this trait. Second, the learning by doing effect in this industry is likely to be on a per plant rather than per megawatt or per turbine basis as has been the case with solar and turbines. The very small unit size for solar and turbine allows for off site factory production with highly repetitive assembly, whereas SMRs will require substantial on-site fabrication that will be site specific. SMR learning rates are more likely to follow those for building construction than other new energy technologies.

Finally, the report does not discuss the risk of catastrophic accidents. The probability of a significant accident is about 1 per 3,700 reactor operating years. Widespread deployment of SMRs will vastly increase the annual risk because that probability is independent of plant size. Building 1,000 SMRs could increase the risk to such a level that these accidents could be happening once every four years.

The Fukushima nuclear plant catastrophe is estimated to have cost $300 billion to $700 billion. The next one could cost in excess of $1 trillion. This risk adds a cost of $11 to $27 per megawatt-hours.

Adding these risk costs on top of the adjusted capacity factor, the cost ranges rises to $65 to $82 per megawatt-hour.

The real lessons from California’s 2000-01 electricity crisis and what they mean for today’s markets

The recent reliability crises for the electricity markets in California and Texas ask us to reconsider the supposed lessons from the most significant extended market crisis to date– the 2000-01 California electricity crisis. I wrote a paper two decades ago, The Perfect Mess, that described the circumstances leading up to the event. There have been two other common threads about supposed lessons, but I do not accept either as being true solutions and are instead really about risk sharing once this type of crisis ensues rather than being useful for preventing similar market misfunctions. Instead, the real lesson is that load serving entities (LSEs) must be able to sign long-term agreements that are unaffected and unfettered directly or indirectly by variations in daily and hourly markets so as to eliminate incentives to manipulate those markets.

The first and most popular explanation among many economists is that consumers did not see the swings in the wholesale generation prices in the California Power Exchange (PX) and California Independent System Operator (CAISO) markets. In this rationale, if consumers had seen the large increases in costs, as much as 10-fold over the pre-crisis average, they would have reduced their usage enough to limit the gains from manipulating prices. Consumers should have shouldered the risks in the markets in this view and their cumulative creditworthiness could have ridden out the extended event.

This view is not valid for several reasons. The first and most important is that the compensation to utilities for stranded assets investment was predicated on calculating the difference between a fixed retail rate and the utilities cost of service for transmission and distribution plus the wholesale cost of power in the PX and CAISO markets. Until May 2000, that difference was always positive and the utilities were well on the way to collecting their Competition Transition Charge (CTC) in full before the end of the transition period March 31, 2002. The deal was if the utilities were going to collect their stranded investments, then consumers rates would be protected for that period. The risk of stranded asset recovery was entirely the utilities’ and both the California Public Utilities Commission in its string of decisions and the State Legislature in Assembly Bill 1890 were very clear about this assignment.

The utilities had chosen to support this approach linking asset value to ongoing short term market valuation over an upfront separation payment proposed by Commissioner Jesse Knight. The upfront payment would have enabled linking power cost variations to retail rates at the outset, but the utilities would have to accept the risk of uncertain forecasts about true market values. Instead, the utilities wanted to transfer the valuation risk to ratepayers, and in return ratepayers capped their risk at the current retail rates as of 1996. Retail customers were to be protected from undue wholesale market risk and the utilities took on that responsibility. The utilities walked into this deal willingly and as fully informed as any party.

As the transition period progressed, the utilities transferred their collected CTC revenues to their respective holding companies to be disbursed to shareholders instead of prudently them as reserves until the end of the transition period. When the crisis erupted, the utilities quickly drained what cash they had left and had to go to the credit markets. In fact, if they had retained the CTC cash, they would not have had to go the credit markets until January 2001 based on the accounts that I was tracking at the time and PG&E would not have had a basis for declaring bankruptcy.

The CTC left the market wide open to manipulation and it is unlikely that any simple changes in the PX or CAISO markets could have prevented this. I conducted an analysis for the CPUC in May 2000 as part of its review of Pacific Gas & Electric’s proposed divestiture of its hydro system based on a method developed by Catherine Wolfram in 1997. The finding was that a firm owning as little as 1,500 MW (which included most merchant generators at the time) could profitably gain from price manipulation for at least 2,700 hours in a year. The only market-based solution was for LSEs including the utilities to sign longer-term power purchase agreements (PPAs) for a significant portion (but not 100%) of the generators’ portfolios. (Jim Sweeney briefly alludes to this solution before launching to his preferred linkage of retail rates and generation costs.)

Unfortunately, State Senator Steve Peace introduced a budget trailer bill in June 2000 (as Public Utilities Code Section 355.1, since repealed) that forced the utilities to sign PPAs only through the PX which the utilities viewed as too limited and no PPAs were consummated. The utilities remained fully exposed until the California Department of Water Resources took over procurement in January 2001.

The second problem was a combination of unavailable technology and billing systems. Customers did not yet have smart meters and paper bills could lag as much as two months after initial usage. There was no real way for customers to respond in near real time to high generation market prices (even assuming that they would have been paying attention to such an obscure market). And as we saw in the Texas during Storm Uri in 2021, the only available consumer response for too many was to freeze to death.

This proposed solution is really about shifting risk from utility shareholders to ratepayers, not a realistic market solution. But as discussed above, at the core of the restructuring deal was a sharing of risk between customers and shareholders–a deal that shareholders failed to keep when they transferred all of the cash out of their utility subsidiaries. If ratepayers are going to take on the entire risk (as keeps coming up) then either authorized return should be set at the corporate bond debt rate or the utilities should just be publicly owned.

The second explanation of why the market imploded was that the decentralization created a lack of coordination in providing enough resources. In this view, the CDWR rescue in 2001 righted the ship, but the exodus of the community choice aggregators (CCAs) again threatens system integrity again. The preferred solution for the CPUC is now to reconcentrate power procurement and management with the IOUs, thus killing the remnants of restructuring and markets.

The problem is that the current construct of the PCIA exit fee similarly leaves the market open to potential manipulation. And we’ve seen how virtually unfettered procurement between 2001 and the emergence of the CCAs resulted in substantial excess costs.

The real lessons from the California energy crisis are two fold:

  • Any stranded asset recovery must be done as a single or fixed payment based on the market value of the assets at the moment of market formation. Any other method leaves market participants open to price manipulation. This lesson should be applied in the case of the exit fees paid by CCAs and customers using distributed energy resources. It is the only way to fairly allocate risks between customers and shareholders.
  • LSEs must be able unencumbered in signing longer term PPAs, but they also should be limited ahead of time in the ability to recover stranded costs so that they have significant incentives to prudently procure resources. California’s utilities still lack this incentive.

Close Diablo Canyon? More distributed solar instead

More calls for keeping Diablo Canyon have coming out in the last month, along with a proposal to match the project with a desalination project that would deliver water to somewhere. (And there has been pushback from opponents.) There are better solutions, as I have written about previously. Unfortunately, those who are now raising this issue missed the details and nuances of the debate in 2016 when the decision was made, and they are not well informed about Diablo’s situation.

One important fact is that it is not clear whether continued operation of Diablo is safe. Unit No. 1 has one of the most embrittled containment vessels in the U.S. that is at risk during a sudden shutdown event.

Another is that the decision would require overriding a State Water Resources Control Board decision that required ending the use of once-through cooling with ocean water. That cost was what led to the closure decision, which was 10 cents per kilowatt-hour at current operational levels and in excess of 12 cents in more likely operations.

So what could the state do fairly quickly for 12 cents per kWh instead? Install distributed energy resources focused on commercial and community-scale solar. These projects cost between 6 and 9 cents per kWh and avoid transmission costs of about 4 cents per kWh. They also can be paired with electric vehicles to store electricity and fuel the replacement of gasoline cars. Microgrids can mitigate wildfire risk more cost effectively than undergrounding, so we can save another $40 billion there too. Most importantly they can be built in a matter of months, much more quickly than grid-scale projects.

As for the proposal to build a desalination plant, pairing one with Diablo would both be overkill and a logistical puzzle. The Carlsbad plant produces 56,000 acre-feet annually for San Diego County Water Agency. The Central Coast where Diablo is located has a State Water Project allocation of 45,000 acre-feet which is not even used fully now. That plant uses 35 MW or 1.6% of Diablo’s output. A plant built to use all of Diablo’s output could produce 3.5 million acre-feet, but the State Water Project would need to be significantly modified to move the water either back to the Central Valley or beyond Santa Barbara to Ventura. All of that adds up to a large cost on top of what is already a costly source of water of $2,500 to $2,800 per acre-foot.

Getting EVs where we need them in multi family and low-income communities

They seem to be everywhere. A pickup rolls up to a dark house in a storm during the Olympics and the house lights come on. (And even powers a product launch event when the power goes out!) The Governator throws lightning bolts like Zeus in a Super Bowl ad touting them. The top manufacturer is among the most valuable companies in the world and the CEO is a cultural icon. Electric vehicles (EVs) or cars are making a splash in the state.

The Ford F-150 Lightning pick up generated so much excitement last summer that it had to increase its initial roll out from 40,000 to 80,000 to 200,000 due to demand. General Motors answered with electric versions of the Silverado and Hummer. (Dodge is bringing up the rear with its Ram and Dakota pickups.)

Much of this has been spurred by California’s EV sales mandates that date back to 1990. The state now plans to phase out the sale of new cars and passenger trucks entirely by 2035, with 35% of sales by 2026. In the first quarter of 2022, EVs were 16% of new car sales.

While EVs look they will be here to stay, the question is where will drivers be able to charge up? That means recharging at home, at work, and on the road when needed. The majority of charging—70% to 80%–occurs at home or at work. Thanks to the abundance of California’s renewable energy, largely from solar power including from rooftops, the most advantageous time is in the middle of the day. The next big hurdle will be putting charging stations where they are needed, most valuable and accessible to those who don’t live in conventional single-family housing.

The state has about 80,000 public and shared private chargers, of which about 10% are DC “fast chargers” that can deliver 80% capacity in about 30 minutes. Yet we likely need 20 times more chargers that what we have today.

Multi-family housing is considered a prime target for additional chargers because of various constraints on tenants such as limitations on installing and owning a charging station and sharing of parking spaces. Community solar panels can be outfitted with charging stations that rely on the output of the panels.

California has a range of programs to provide incentives and subsidies for installing chargers. Funding for another 5,000 chargers was recently authorized. The state funds the California Electric Vehicle Infrastructure Project (CALeVIP) that provides direct incentives and works with local partners plan and install Level 2 and DC fast charging infrastructure. This program has about $200 million available. The program has 13 county and regional projects that contribute $6,000 and more for Level 2 chargers and often $80,000 for a DC fast charger. A minimum of 25% of funds are reserved for disadvantaged and low-income communities. In many cases, the programs are significantly oversubscribed with waiting lists, but the state plans to add enough funding for an additional 100,000 charging stations in the 2022-23 fiscal year, with $900 million over the next four years.

California’s electric utilities also fund charging projects, although those programs open and are quickly oversubscribed.

  • Southern California Edison manages the Charge Ready program with a focus on multi-family properties including mobilehome parks. The program offers both turn-key installation and rebates. SCE’s website provides tools for configuring a parking lot for charging.
  • San Diego Gas & Electric offered Power Your Drive to multi-family developments, with 255 locations currently. SDG&E has added the Power Your Drive Extension to add another 2,000 charging stations over the next two years. SDG&E will provide up to $12,000 for Level 2 chargers and additional maintenance funding.
  • Pacific Gas & Electric offered the EV Charge program in which PG&E will pay for, own, maintain and coordinate construction of infrastructure from the transformer to the parking space, as well as support independent ownership and operation. The program is not currently taking applications however. PG&E’s website offers other tools for assessing the costs and identifying vendors for installing chargers.
  • PG&E is launching a “bidirectional” EV charging pilot program with General Motors that will test whether EVs can be used to improve electric system reliability and resilience by using EVs as back up energy storage. The goal is to extend the program by the end of 2022. This new approach may provide EV owners with additional value beyond simply driving around town. PG&E also is setting up a similar pilot with Ford.
  • Most municipally-owned electric utilities offer rebates and incentives as well..

Community residents have a range of incentives available to them to purchase an EV.

  • The state offers $750 through the Clean Fuel Reward on the purchase of a new EV. .
  • California also offers the Clean Vehicle Rebate Project that offers $1,000 to $7,000 for buying or leasing a (non-Tesla) to households making less than $200,000 or individuals making less than $135,000. Savings depend on location and vehicle acquired.
  • Low-income households can apply for a state grant to purchase a new or used electric or hybrid vehicle, plus $2,000 for a home charging station, through the Clean Vehicle Assistance Program. The income standards are about 50% higher than those establishing eligibility for the CARE utility rate discount. The average grant is about $5,000.
  • The federal government offers a tax credit of up to $7,500 depending on the make and model of vehicle.
  • Car owners also can scrap their gasoline-fueled cars for $1,000 to $1,500, depending on household income.
  • Several counties, including San Diego and Sonoma, have offered EV purchase incentives to county residents. Those programs open and fill fairly quickly.

The difference between these EVs coming down the road (yes, that’s a pun) and the current models is akin to the difference between flip phones and smart phones. One is a single function communication device, and we use the latter to manage our lives. The marketing of EVs could shift course to emphasize these added benefits that are not possible with a conventional vehicle. We can expect a similar transformation in how we view energy and transportation as the communication and information revolution.

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.

Guidelines For Better Net Metering; Protecting All Electricity Customers And The Climate

Authors Ahmad Faruqui, Richard McCann and Fereidoon Sioshansi[1] respond to Professor Severin Borenstein’s much-debated proposal to reform California’s net energy metering, which was first published as a blog and later in a Los Angeles Times op-ed.

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

PG&E takes a bold step on enabling EV back up power, but questions remain

PG&E made exciting announcements about partnerships with GM and Ford last week to test using electric vehicles (EVs) for backup power for residential customers. (Ford also announced an initiative to create an open source charging standard.) PG&E also announced an initiative to install circuit breakers that facilitate use of onsite backup power. PG&E is commended for stepping forward to align its corporate strategy with the impending technology wave that could increase consumer energy independence.

I wrote about the promise of EVs in this role (“Electric vehicles as the next smartphone”) when I was struck by Ford’s F-150 Lightning ads last summer and how the consumer segment that buys pickups isn’t what we usually think of as the “EV crowd.” These initiatives could be game changers.

That said, several questions arise about PG&E’s game plan and whether the utility is still planning to hold customers captive:

  • How does PG&E plan to recover the costs for what are “beyond the meter” devices that typically is outside of what’s allowed? And how are the risks in these investments to be shared between shareholders and ratepayers? Will PG&E get an “authorized” rate of return with default assurances of costs being approved for recovery from ratepayers? How will PG&E be given appropriate incentives on making timely investments with appropriate risk, especially given the utility’s poor track record in acquiring renewable resources?
  • What will be the relationships between PG&E and the participating auto manufacturers? Will the manufacturers be required to partner with PG&E going forward? Will the manufacturers be foreclosed from offering products and services that would allow customers to exit PG&E’s system through self generation? Will PG&E close out other manufacturers from participating or set up other access barriers that prevent them from offering alternatives?
  • Delivering PG&E’s “personal microgrid backup power transfer meter device” is a good first step, but it requires disconnecting the solar panels to use, which means that it only support fossil fueled generators and grid-connected batteries. This device needs a switch for the solar panels as well. Further, it appears the device will only be available to customers who participate in PG&E’s Residential Generator and Battery Rebate Program. Can PG&E continue to offer this feature to vendors who offer only fossil-fueled generators? How will PG&E mitigate the local air pollution impacts from using fossil-fueled back up generators (BUGs) for extended periods? (California already has 8,000 megawatts of BUGs.)
  • How will these measures be integrated with the planned system reinforcements in PG&E’s 2022 Wildfire Mitigation Plan Update to reduce the costs of undergrounding lines? Will PG&E allow these back up sources and devices for customers who are interested in extended energy independence, particularly those who want to ride out a PSPS event?
  • How will community choice aggregators (CCAs) or other local governments participate? Will communities be able to independently push these options to achieve their climate action and adaptation plan (CAAP) goals?

A cheaper wildfire mitigation solution: using microgrids instead of undergrounding

PG&E released its 2022 Wildfire Mitigation Plan Update (2022 WMPU) That plan calls for $6 billion of capital investment to move 3,600 miles of underground by 2026. This is just over a third of the initial proposed target of 10,000 miles. Based on PG&E’s proposed ramping up, the utility would reach its target by 2030.

One alternative that could better control costs would be to install community and individual microgrids. Microgrids are likely more cost effective and faster means of reducing wildfire risk and saving lives. I wrote about how to evaluate this choice for relative cost effectiveness based on density of load and customers per mile of line.

Microgrids can mitigate wildfire risk by the utility turning off overhead wire service for extended periods, perhaps weeks at a time, during the highest fire risk periods. The advantage of a periodically-islanded microgrid is 1) that the highest fire risk coincides with the most solar generation so providing enough energy is not a problem and 2) the microgrids also can be used during winter storms to better support the local grid and to ride out shorter outages. Customers’ reliability may degrade because they would not have the grid support, but such systems generally have been quite reliable. In fact, reliability may increase because distribution grid outages are about 15 times more likely than system or regional outages.

The important question is whether microgrids can be built much more quickly than undergrounding lines and in particular whether PG&E has the capacity to manage such a buildout at a faster rate? PG&E has the Community Microgrid Enablement Program. The utility was recently authorized to build several isolated microgrids as an alternative to rebuilding fire-damaged distribution lines to isolated communities. Turning to local governments to manage many different construction projects likely would improve this schedule, like how Caltrans delegates road construction to counties and cities.

Controlling the costs of wildfire mitigation

Based on the current cost of capital this initial undergrounding phase will add $1.6 billion to annual revenue requirements or an additional 8% above today’s level. This would be on top of PG&E request in its 2023 General Rate Case for a 48% increase in distribution rates by 2023 and 78% increase by 2026, and a 31% increase in overall bundled rates by 2023 and 43% by 2026. The 2022 WMPU would take the increase to over 50% by 2026 (and that doesn’t’ include the higher maintenance costs). That means that residential rates would increase from 28.7 cents per kilowatt-hour today (already 21% higher than December 2020) to 36.4 cents in 2026. Building out the full 10,000 miles could lead to another 15% increase on top of all of this.

Turning to the comparison of undergrounding costs to microgrids, these two charts illustrate how to evaluate the opportunities for microgrids to lower these costs. PG&E states the initial cost per mile for undergrounding is $3.75 million, dropping to $2.5 million, or an average of $2.9 million. The first figure looks at community scale microgrids, using National Renewable Energy Laboratory (NREL) estimates. It shows how the cost effectiveness of installing microgrids changes with density of peak loads on a circuit on the vertical axis, cost per kilowatt for a microgrid on the horizontal axis, and each line showing the division where undergrounding is less expensive (above) or microgrids are less expensive (below) based on the cost of undergrounding. As a benchmark, the dotted line shows the average load density in the PG&E system, combined rural and urban. So in average conditions, community microgrids are cheaper regardless of the costs of microgrids or undergrounding.

The second figure looks at individual residential scale microgrids, again using NREL estimates. It shows how the cost effectiveness of installing microgrids changes with customer density on a circuit on the vertical axis, cost per kilowatt for a microgrid on the horizontal axis, and each line showing the division where undergrounding is less expensive (above) or microgrids are less expensive (below). As a benchmark, the dotted line shows the average customer density in the PG&E system, combined rural and urban. Again, residential microgrids are less expensive in most situations, especially as density falls below 75 customers per mile.

A movement towards energy self-sufficiency is growing in California due to a confluence of factors. PG&E’s WMPU should reflect these new choices in manner that can reduce rates for all customers.

(Here’s my testimony on this topic filed by the California Farm Bureau in PG&E’s 2023 General Rate Case on its Wildfire Management Plan Update.)

Why utility prices cannot be set using short-run marginal costs

One commentator on the Energy Institute at Haas’ blog entitled “Everyone Should Pay a ‘Solar Tax’” points out that one version of economic theory holds that short run marginal cost is the appropriate metric for composing efficient prices. And he points out that short-run (SRMC) and long-run marginal costs (LRMC) should converge in equilibrium. So he implicitly says that long run marginal costs are the appropriate metric if as a stable long-run measure is based, as he states, on forecasts.

Even so, he misses an important aspect–using the SRMC for pricing relies on important conditions such as (1) relatively free entry and exit, (2) producers bear full risk for their investments, and (3) no requirements exist for minimum supply (i.e., no reserve margins). He points out that utilities overbuild their transmission and distribution (and I’ll point out their generation) systems. I would assert that is because of the market failures related to the fact that the conditions I listed above are missing–entry is restricted or prohibited, customers bear almost all of the risk, and reserve margins largely eliminates any potential for scarcity rents. In fact, California explicitly chose its reserve margin and resource adequacy procurement standards to eliminate the potential for pricing in the scarcity rents necessary for SRMC and LRMC to converge.

He correctly points out that apparent short run MC are quite low (not quite as close to zero as he asserts though)–a statement that implies that he expects that SRMC in a correctly functioning market would be much higher. In fact, as he states, the SRMC should converge to the LRMC. The fact is that SRMC has not risen to the LRMC on an annual average basis in decades in California (briefly in 2006, 2001 and 2000 (when generators exerted market power) and then back to the early 1980s). So why continue to insist that we should be using the current, incorrect SRMC as the benchmark when we know that it is wrong and we specifically know why its wrong? That we have these market failures to maintain system reliability and address the problems of network and monopolistic externalities is why we have regulation.

The solution is not to try to throw out our current regulatory scheme and then let the market price run free in the current institutional structure with a single dominant player. Avoiding market dominance is the raison d’etre for economic regulation. If that is the goal, the necessary first step is introducing and sustaining enough new entrants to be able to discipline the behavior of the dominant firm. Pricing reform must follow that change, not precede it. Competitive firms will not just spontaneously appear due to pricing reform.

It’s not clear that utilities “must” recover their “fixed” investments costs. Another of the needed fixes to the current regulatory scheme to improve efficiency is having utilities bear the risks of making incorrect investment decisions. Having warned (correctly) the IOUs about overforecasting demand growth for more than a dozen years now, they will not listen such analyses unless they have a financial incentive to do so.

Contrary to claims by this and other commentators, It is not efficient to charge customers a fixed charge beyond the service connection cost (which is about $10/month for residential customers for California IOUs). If the utility charges a fixed cost for the some portion of the rest of the grid, the efficient solution must then allow customers to sell their share of that grid to other customers to achieve Pareto optimal allocations among the customers. We could set up a cumbersome, high transaction cost auction or bulletin board to facilitate these trades, but there is at least another market mechanism that is nearly as efficient with much lower transaction costs–the dealer. (The NYSE uses a dealer market structure with market makers acting as dealers.) In the case of the utility grid, the utility that operates the grid also can act as the dealer. The most likely transaction unit would bein kilowatt-hours. So we’re left back where we started with volumetric rates. The problem with this model is not that it isn’t providing sufficient revenue certainty–that’s not an efficiency criterion. The problem is that the producer isn’t bearing enough of the risk of insufficient revenue recovery.

An alternative solution may be to set the distribution volumetric rate at the LRMC with no assurance of revenue requirement on that portion, and then recover the difference between average cost and LRMC in a fixed charge. This is the classic “lump sum” solution to setting monopoly pricing. The issue has been how to allocate those lump sum payments. However, the true distribution LRMC appears to be higher than average costs now based on how average rates have been rising.