Tag Archives: energy economics

U. of Chicago misses mark on evaluating RPS costs

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The U. of Chicago just released a working paper “Do Renewable Portfolio Standards Deliver?” that purports to assess the added costs of renewable portfolio standards adopted by states. The paper has two obvious problems that make the results largely useless for policy development purposes.

First, it’s entirely retrospective and then tries to make conclusions about future actions. The paper ignores that the high initial costs for renewables was driven down by a combination of RPS and other policies (e.g. net energy metering or NEM), and on a going forward basis, the renewables are now cost competitive with conventional resources. As a result, the going forward cost of GHG reductions is much smaller than the historic costs. In fact, the much more interesting question is “what would be the average cost of GHG reductions by moving from the current low penetration rate of renewables to substantially higher levels across the entire U.S., e.g., 50%, 60% etc. to 100%?” The high initial investment costs are then highly diluted by the now cost effective renewables.

Second, the abstract makes this bizarre statement “(t)hese cost estimates significantly exceed the marginal operational costs of renewables and likely reflect costs that renewables impose on the generation system…” Um, the marginal “operational” costs of renewables generally is pretty damn close to zero! Are the authors trying to make the bizarre claim (that I’ve addressed previously) that renewables should be priced at their “marginal operational costs”? This seems to reflect an remarkable naivete on the part of the authors. Based on this incorrect attribution, the authors cannot make any assumptions about what might be causing the rate difference.

Further, the authors appear to attribute the entire difference in rates to imposing an RPS standard. The fact is that these 29 states generally have also been much more active in other efforts to promote renewables, including for customers through NEM and DER rates, and to reduce demand. All of these efforts reduce load, which means that fixed costs are spread over a fewer amount of kilowatt-hours, which then causes rates to rise. The real comparison should be the differences in annual customer bills after accounting for changes in annual demand.

The authors also try to assign stranded cost recovery as a cost of GHG recovery. This is a questionable assignment since these are sunk costs which economists typically ignore. If we are to account for lost investment due to obsolescence of an older technology, economists are going to have go back and redo a whole lot of benefit-cost analyses! The authors would have to explain the special treatment of these costs.

Why do economists keep producing these papers in which they assume the world is static and that the future will be just like the past, even when the evidence of a rapidly changing scene is embedded in the data they are using?

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Moving beyond the easy stuff: Mandates or pricing carbon?

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Meredith Fowlie at the Energy Institute at Haas posted a thought provoking (for economists) blog on whether economists should continue promoting pricing carbon emissions.

I see, however, that this question should be answered in the context of an evolving regulatory and technological process.

Originally, I argued for a broader role for cap & trade in the 2008 CARB AB32 Scoping Plan on behalf of EDF. Since then, I’ve come to believe that a carbon tax is probably preferable over cap & trade when we turn to economy wide strategies for administrative reasons. (California’s CATP is burdensome and loophole ridden.) That said, one of my prime objections at the time to the Scoping Plan was the high expense of mandated measures, and that it left the most expensive tasks to be solved by “the market” without giving the market the opportunity to gain the more efficient reductions.

Fast forward to today, and we face an interesting situation because the cost of renewables and supporting technologies have plummeted. It is possible that within the next five years solar, wind and storage will be less expensive than new fossil generation. (The rest of the nation is benefiting from California initial, if mismanaged, investment.) That makes the effective carbon price negative in the electricity sector. In this situation, I view RPS mandates as correcting a market failure where short term and long term prices do not and cannot converge due to a combination of capital investment requirements and regulatory interventions. The mandates will accelerate the retirement of fossil generation that is not being retired currently due to mispricing in the market. As it is, many areas of the country are on their way to nearly 100% renewable (or GHG-free) by 2040 or earlier.

But this and other mandates to date have not been consumer-facing. Renewables are filtered through the electric utility. Building and vehicle efficiency standards are imposed only on new products and the price changes get lost in all of the other features. Other measures are focused on industry-specific technologies and practices. The direct costs are all well hidden and consumers generally haven’t yet been asked to change their behavior or substantially change what they buy.

But that all would seem to change if we are to take the next step of gaining the much deeper GHG reductions that are required to achieve the more ambitious goals. Consumers will be asked to get out of their gas-fueled cars and choose either EVs or other transportation alternatives. And even more importantly, the heating, cooling, water heating and cooking in the existing building stock will have to be changed out and electrified. (Even the most optimistic forecasts for biogas supplies are only 40% of current fossil gas use.) Consumers will be presented more directly with the costs for those measures. Will they prefer to be told to take specific actions, to receive subsidies in return for higher taxes, or to be given more choice in return for higher direct energy use prices?

Reverse auctions for storage gaining favor

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Two recent reports highlight the benefits of using “reverse auctions”. In a reverse auction, the buyer specifies a quantity to be purchased, and sellers bid to provide a portion of that quantity.  An article in Utility Dive summarizes some of the experiences with renewable market auctions.  A separate report in the Review of Environmental Economics and Policy goes further to lay out five guidelines:

  1. Encourage a Large Number of Auction Participants
  2. Limit the Amount of Auctioned Capacity
  3. Leverage Policy Frameworks and Market Structures
  4. Earmark a Portion of Auctioned Capacity for Less-mature Technologies
  5. Balance Penalizing Delivery Failures and Fostering Competition

This policy prescription requires well-informed policy makers balancing different factors–not a task that is well suited to a state legislature. How to develop such a coherent policy can done in two ways. The first is to let the a state commission work through a proceeding to set an overall target and structure. But perhaps a more fruitful approach would be to let local utilities, such as California’s community choice aggregators (CCAs) to set up individual auctions, maybe even setting their own storage targets and then experimenting with different approaches.

California has repeatedly made errors by overly relying on centralized market structures that overcommit or mismatch resource acquisition. This arises because a mistake by a single central buyer is multiplied across all load while a mistake by one buyer within a decentralized market is largely isolated to the load of that one buyer. Without perfect foresight and a distinct lack of mechanisms to appropriately share risk between buyers and sellers, we should be designing an electricity market that mitigates risks to consumers rather than trying to achieve a mythological “optimal” result.

Relying on short term changes diminishes the promise of energy storage

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I posted this response on EDF’s blog about energy storage:

This post accepts too easily the conventional industry “wisdom” that the only valid price signals come from short term responses and effects. In general, storage and demand response is likely to lead to increased renewables investment even if in the short run GHG emissions increase. This post hints at that possibility, but it doesn’t make this point explicitly. (The only exception might be increased viability of baseloaded coal plants in the East, but even then I think that the lower cost of renewables is displacing retiring coal.)

We have two facts about the electric grid system that undermine the validity of short-term electricity market functionality and pricing. First, regulatory imperatives to guarantee system reliability causes new capacity to be built prior to any evidence of capacity or energy shortages in the ISO balancing markets. Second, fossil fueled generation is no longer the incremental new resource in much of the U.S. electricity grid. While the ISO energy markets still rely on fossil fueled generation as the “marginal” bidder, these markets are in fact just transmission balancing markets and not sources for meeting new incremental loads. Most of that incremental load is now being met by renewables with near zero operational costs. Those resources do not directly set the short-term prices. Combined with first shortcoming, the total short term price is substantially below the true marginal costs of new resources.

Storage policy and pricing should be set using long-term values and emission changes based on expected resource additions, not on tomorrow’s energy imbalance market price.

A counter to UC’s skepticism about CCAs

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Kevin Novan from UC Davis wrote an article in the University of California Giannini Foundation’s Agriculture and Resource Economics Update entitled “Should Communities Get into the Power Marketing Business?” Novan was skeptical of the gains from community choice aggregation (CCA), concluding that continued centrally planned procurement was preferable. Other UC-affiliated energy economists have also expressed skepticism, including Catherine Wolfram, Severin Borenstein, and Maximilian Auffhammer.

At the heart of this issue is the question of whether the gains of “perfect” coordination outweigh the losses from rent-seeking and increased risks from centralized decision making. I don’t consider myself an Austrian economist, but I’m becoming a fan of the principle that the overall outcomes of many decentralized decisions is likely to be better than a single “all eggs in one basket” decision. We pretend that the “central” planner is somehow omniscient and prudently minimizes risks. But after three decades of regulatory practice, I see that the regulators are not particularly competent at choosing the best course of action and have difficulty understanding key concepts in risk mitigation.By distributing decision making, we better capture a range of risk tolerances and bring more information to the market place. There are further social gains from dispersed political decision making that brings accountability much closer to home and increases transparency. Of course, there’s a limit on how far decentralization should go–each household can’t effectively negotiate separate power contracts. But we gain much more information by adding a number of generation service providers or “load serving entities” (LSE) to the market.

I found several shortcomings with with Novan’s article that would change the tenor. I take each in turn:

  • He wrote “it remains to be seen whether local governments will make prudent decisions…” However, he did not provide the background which explains at least in part why the CCAs have arisen in the first place. Largely over the last 40 years, the utilities have made imprudent procurement and planning decisions. Whether those have been pushed on the utilities by the CPUC and Legislature or whether the IOUs have some responsibility, the fact is that neither institution sees real consequences for these decisions, neither financially or politically. In fact, the one time that a CPUC commissioner attempted to deliver consequences to the IOUs, she was fired and replaced by a former utility CEO. The appropriate comparison for local government decision making is to the current baseline record, not an academic hypothetical that will never exist. And by the way, government enterprise agencies, including municipal utilities, have a relatively good record as demonstrated as by lower electricity rates and relatively well managed, almost invisible capital intensive water and sanitation utilities. The current CCAs have a more extensive portfolio risk management system than PG&E—my calculation of PG&E’s implicit risk hedge in its renewables portfolio is an astounding 3.3 cents per kilowatt-hour.
  • Novan complains that CCAs have “dual objectives.” In fact they have “triple objectives,” the added one to encourage local economic development (sometimes through lower rates). I suggest reading the mission statements of the CCAs that have been created, including the local Valley Clean Energy Authority .
  • It’s not clear that “purchasing locally produced renewable energy will likely lead to more expensive renewable output” for at least two reasons. The first is that local power can avoid further transmission investment. The current CAISO transmission access charges range from $11 to $39 per megawatt-hour and is forecasted to continue to rise significantly (indicating transmission marginal costs are much above average costs). In a commentary on a UC Energy Institute blog, it was revealed that the Sunrise line may have cost as much as $80 per MWH for power from the desert. This wipes out much of the difference between utility scale and DG solar power. Building locally avoids yet more expensive transmission investment to the southeast desert. [I worked on the DRECP for the CEC.] In addition, local power can avoid distribution investment and will be reflected in the IOU’s distribution resource plans (DRP). And second, the scale economies for solar PV plants largely disappears after about 10 MW. So larger plants don’t necessarily mean cheaper, (especially if they have to implement more extensive environmental mitigation.) [I prepared the Cost of Generation model and report for the CEC from 2001-2013.]
  • It’s not necessary that more renewable capacity is needed for local generation. The average line losses in the CAISO system are about 6%, and those are greater from the far desert region. Whether increased productivity overcomes that difference is an empirical question that I haven’t seen answered satisfactorily yet.
  • Novan left unstated his premise defining “greener” renewables, but I presume that it’s based almost entirely on GHG emissions. However, local power is likely “greener” because it avoids other environmental impacts as well. Local renewables are much more likely to be built on brownfields and even rooftops so there’s not added footprints. In contrast there is growing opposition to new plants in the desert region. The second advantage is the avoidance of added transmission corridors. One only needs to look at the Sunrise and Tehachipi lines to see how those consequences can slow down the process. Local DG can avoid distribution investment that has consequences as well. Further, local power provides local system support that can displace local natural gas generation. In fact, one of the key issues for Southern California is the need to maintain in-basin generation to support imports of renewables across the LA Basin interface. [I assessed the need for local generation in the LA Basin in the face of various environmental regulations for the CEC.]

I was on the City of Davis Community Choice Energy Advisory Committee, and I am testifying on behalf of the California CCAs on the setting of the PCIA in several dockets. I have a Ph.D. from Berkeley’s ARE program and have worked on energy, environmental and water issues for about 30 years.

 

 

 

 

CCAs reach RPS targets with long-term PPAs

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As I listen to the opening of the joint California Customer Choice En Banc held by the CPUC and CEC, I hear Commissioners and speakers claiming that community choice aggregators (CCAs) are taking advantage of the current market and shirking their responsibilities for developing a responsible, resilient resource portfolio.

The CPUC’s view has two problems. The first is an unreasonable expectation that CCAs can start immediately as a full-grown organization with a complete procurement organization, and more importantly, a rock solid credit history. The second is how the CPUC has ignored the fact that the CCAs have already surpassed the state’s RPS targets  in most cases and that they have significant shares of long-term power purchase agreements (PPAs).

State law in fact penalizes excess procurement of RPS-eligible power by requiring that 65% of that specific portfolio be locked into long-term PPAs, regardless of the prudency of that policy. PG&E has already demonstrated that they have been unable to prudently manage its long-term portfolio, incurring a 3.3 cents per kilowatt-hour risk hedge premium on its RPS portfolio. (Admittedly, that provision could be interpreted to be 65% of the RPS target, e.g., 21.5% of a portfolio that has met the 33% RPS target, but that is not clear from the statute.)