Tag Archives: M.Cubed

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?

 

 

 

 

End the fiction of regulatory oversight of California’s generation

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M.Cubed is the only firm willing to sign the non-disclosure agreements (NDA) that allow us to review the investor-owned utilities’ (IOUs) generation portfolio data on behalf of outside intervenors, such as the community choice aggregators (CCAs). Even the direct access (DA) customers who constitute about a quarter of California’s industrial load are represented by a firm that is unwilling to sign the NDAs. This situation places departed load customers, and in fact all customers, at a distinct disadvantage when trying to regulate the actions of the IOUs. It is simply impossible for a single small firm to scrutinize all of the filings and data from the IOUs. (Not to mention that one, SDG&E, gets a complete free pass for now as that it has no CCAs.)

This situation has arisen because the NDAs require that the “reviewing representatives” not be in a position to advise market participants, such as CCAs or energy service providers (ESPs) that sell to DA customers, on procurement decisions. This is an outgrowth of AB 57 in 2002, a state law passed to bring IOUs back into the generation market after the collapse of restructuring in 2001. That law was intended to the balance of power to the IOUs away from generators for procurement purposes. Now it puts the IOUs at a competitive advantage against other load serving entities (LSEs) such as CCAs and ESPs, and even bundled customers.

This imbalance has arisen for several insurmountable reasons:

  • No firm can build its business on serving only to review IOU filings without offering other procurement consulting services to clients.
  • It is difficult to build expertise for reviewing IOU filings without participating in procurement services for other LSEs or resource providers. (I am uniquely situated by the consulting work I did for the CEC on assessing generation technology costs for over a decade.)
  • CPUC staff similarly lacks the expertise for many of the same reasons, and are relatively ineffective at these reviews. The CPUC is further limited by its ability to recruit sufficient qualified staff for a variety of reasons.

If California wants to rein in the misbehavior by IOUs (such as what I’ve documented on past procurement and shareholder returns earlier), then we have two options to address this problem going forward:

  1. Transform at least the power generation management side of the IOUs into publicly owned entities with more transparent management review.
  2. End the annual review and setting of PCIA and CTC rates by establishing one-time prepayment amounts. By prepaying or setting a fixed annual amount, the impact of accounting maneuvers are diminished substantially, and since IOUs can no longer shift portfolio management risks to departed load customers, the IOUs more directly face the competitive pressures that should make them more efficient managers.

Moving forward on Flood-MAR with pilots

The progress on implementing floodwater managed aquifer recharge programs (Flood-MAR) reminds me of the economist’s joke, “sure it works in practice, but does it work in theory?” A lot of focus seems to be on trying to refine the technical understanding of recharge, without going with what we already know about aquifer replenishment from decades of applications.

The Department of Water Resources Flood-MAR program recently held a public forum to discuss its research program. I presented a poster (shown above) on the findings of a series of studies we conducted for Sustainable Conservation on the economic and financial considerations for establishing these programs. (I posted about this last February.)

My conclusion from the presentations and the other publications we’ve followed is that the next step is to set up pilots using different institutional set ups and economic incentives. The scientists and engineers can further refine their findings, but we generally know where the soils are better for percolation versus others, and we know that crop productivity won’t fall too much where fields are flooded. The real issues fall into five categories, of which we’ve delved into four in our Floodwater Recharge Memos.

Benefits Diagrams_Page_5

The first is identifying the beneficiaries and the potential magnitude of those benefits. As can be seen in the flow chart above, there many more potential beneficiaries than just the local groundwater users. Some of these benefits require forecast informed reservoir operations (FIRO) to realize those gains through reduced flood control space, increased water supply storage and greater summertime hydropower output. Flood-MAR programs can provide the needed margin of error to lower the risk from FIRO.

FloodMAR Poster - Financing

The second is finding the funding mechanisms to compensate growers or to build dedicated recharge basins. We prepared a list of potential financing mechanisms linked to the potential beneficiaries. (This list grew out of another study that we prepared for the Delta Protection Commission on feasible options for beneficiary-pays financing.)

FloodMAR Poster Incentives

The third is determining what type of market incentive transactions mechanisms would work best at attracting the most preferred operations and acreage. I have explored the issues of establishing unusual new markets for a couple of decades, including for water rights transfer and air quality permit trading. It is not a simple case of “declaring markets exist” and then walking away. Managing institutions have important roles in setting up, running and funding any market, and most particularly for those that manage what were “public goods” that individuals and firms were able to use for free. The table above lists the most important considerations in establishing those markets.

The fourth assessing what type of infrastructure investment will produce the most cost-effective recharge. Construction costs (which we evaluated) is one aspect, and impacts on agricultural operations and financial feasibility are other considerations. The chart at the top summarizes the results from comparing several case studies. These will vary by situation, but remarkably, these options appear to cost substantially less than any surface storage projects currently being proposed.

The final institutional issue to be addressed, but not the least important, is determining the extent of rights over floodwaters and aquifers. California state law and regulations are just beginning to grapple with these issues. Certain areas are beginning to assert protection of their existing rights. This issue probably represents the single biggest impediment to these programs before attracting growers to participate.

All of these issues can be addressed in a range of pilot programs which use different variables to test which are likely to be more successful. Scientists and engineers can use these pilots to test for the impacts of different types of water diversion and application. Statistical regression analysis can provide us much of what we know without having to understand the hydrological dynamics. Legal rights can be assessed by providing temporary permits that might be modified as we learn more from the pilots.

Is it time to move forward with local pilot programs? Do we know enough that we can demonstrate the likely benefits? What other aspects should we explore before moving to widespread adoption and implementation?

Non-Profit Utilities Could Cure What Ails California Electricity

electricservicearea

Severin Borenstein at the Energy Institute at Haas, asks “Would Non-Profit Utilities Cure What Ails California Electricity?” I am posting my response here as that I find his post overlooks several important points and distinctions.

I’ll start by saying I wrote an op-ed in the Sacramento Bee in the early 2000s noting that creating a new municipal utility was not going to deliver the same low rates as existing munis and I’m still aware that such a transfer is unlikely to reduce rates much. But it does change the governance structure in a way that is likely to be more accountable and less influenced by the private interests of utility shareholders. Communities are joining together to push for acquisition of PG&E by a cooperative, which would have a similar governance structure to a municipal utility.

First, the complaint about government is largely about agencies that I will call “ministerial” or “administrative”. These agencies issue permits and licenses or provide social services. In contrast, the government agencies that deliver utility services, which are “enterprises” largely deliver service with few complaints. About 80% of water utilities and almost all wastewater utilities are publicly owned. I work in the water arena as well, and the only utility that I hear complaints about from customers is LADWP (both water and power sides). (The SDCWA-MWD fight is between agencies’ managements, not from customers). On the other hand, all three or California’s electric IOUs are the target of customers’ ire. And the IOU staffs (which I have frequent contact with) are no better than government employees in their responsiveness or competence. One advantage the enterprise agencies have over the ministerial/administrative ones is that they generally pay a higher salary so employees are motivated in much the same way as those in the private sector. Moving from oversight by a ministerial/administrative agency (CPUC) to management by an enterprise utility should overcome the problem of recruiting competent motivated staff.

Second, shareholders shoulder very little risk now, particularly in California. I testified in the IOUs’ rate of return case and we asked for the amount of disallowances that shareholders had to bear over the last two decades. Other than SDG&E’s 2007 wildfire costs due to negligence on the utility’s part, they came pack with amounts that were in the tens of millions, which amounts to less than a 0.1% of their revenues collected over that period. Utilities’ generation investment is now so protected that the CPUC reversed itself last year and removed the 10 year recovery cap from exit fees for generation that the utilities built knowing the cap existed. They are now getting bonus dollars! (Same thing happened with Diablo Canyon in 1996.) Yet the utilities are claiming in that rate case that the return on equity should be increased even further! I have a blog post about how the current return is already too high. (Part 2 is the next day.)  Public ownership in contrast can reduce the return on capital from close to 10% (before tax) to 5% or less, which can cut rates substantially.

We can see how PG&E in particular has been incompetently managed for decades. I posted about its many foibles since the 1960s as well. The supposed incentives and efficiencies of the private sector have failed to materialize for California utilities, and meanwhile we pay higher costs for capital with no real risk mitigation. (Ratepayers still had to pay for PG&E’s debts after the 2000-01 energy crisis, and it looks like the same may happen again.)

Finally, the question arises as to whether municipalizing piecemeal would create inequities. The premise of the statement is that the current economic distribution is equitable. But the fact is that rural residential customers in the wildland/urban interface (WUI) have not been paying their full share of their costs and have been heavily subsidized by urban customers. Those customers in the WUI tend to be better off than average (poor rural customers are more likely to live in agricultural communities that are not subject to the same fire risks and for whom service costs are lower), so we already have an adverse wealth transfer in place. And those subsidies have facilitated expansion of housing into those high risk areas that also encourage longer commutes with more GHG emissions.

The better question is how can the rural service areas be better served in the future without relying on the traditional utility structure? Moving toward microgrids and other DER solutions to improve reliability while reducing fire risk is one solution. Spending a $100 billion on undergrounding lines to be paid for by everyone else is NOT a good solution.

Utilities’ returns are too high (Part 1)

IOU share prices

An analysis of equity market activity indicates that investors have not priced a risk discount into California utility shares, and instead, until the recent wildfires, utility investors have placed a premium value on California utility stocks. This premium value indicates that investors have viewed California as either less risky than other states’ utilities or that California has provided a more lucrative return on investment than other states.

The California Public Utilities Commission (CPUC) should set the authorized return on equity to shareholders (ROE) to deliver an after-tax net income amount as a percentage of the capital invested by the utility or the “book value.” As Alfred Kahn wrote, “the sharp appreciation in the prices of public utility stocks, to one and half and then two times their book values during this period [the 1960s] reflected also a growing recognition that the companies in question were in fact being permitted to earn considerably more than their cost of capital.” (see footnote 69)

The book value is fairly stable and tends to grow over time as higher cost capital is invested to meet growth and to replace older, lower cost equipment. Investors use this forecasted income to determine their valuation of the company’s common stock in market transactions. Generally the accepted valuation is the net present value of the income stream using a discount rate equal to the expected return on that investment. That expected return represents the market-based return on equity or the implied market return.

The Commission should generally target the ROE so that the book and market values of the utility company are roughly comparable. In that way, when the utility adds capital, that capital receives a return that closely matches the return investors expect in the market place. If the regulated ROE is low relative to the market ROE, the company will have difficulty raising sufficient capital from the market for needed investments. If the regulated ROE is high relative to the market ROE, ratepayers will pay too much for capital invested and excess economic resources will be diverted into the utility’s costs. On this premise, we compared each of the utilities’ market valuation and implied market ROE against market baskets of U.S. utilities and the current authorized ROEs.

The figure above shows how the stock price for each of the three California utility holding companies (PG&E Corporation (ticker symbol PCG), Edison International (EIX) and Sempra (SRE)) that own the four large California energy utilities. The figure compares these stock prices to the Dow Jones Utility index average from June 1998 to July 2019 starting from a common base index value of 100 on January 1, 2000. The chart also includes (a) important Commission decisions and state laws that have been enacted and are identified by several of the utility witnesses as increasing the legal and regulatory risk environment in the state, and (b) catastrophic events at particular utilities that could affect how investors perceive the risk and management of that utility.

Table 1 summarizes the annual average growth in share prices for the Dow Jones Utility average and the three holding companies up to the 2012 cost of capital decision, the 2017 cost of capital modification decision, and to July 2019. Also of particular note, the chart includes the Commission’s decision on incorporating a risk-based framework into each utility’s General Rate Case process in D.14-12-025. The significance of this decision is that the utility’s consideration of safety risk was directed to be “baked in” to future requests for new capital investment. The updated risk framework also has the impact of making new these new investments more secure from an investment perspective, since there is closer financial monitoring and tracking.

As you can see in both Table 1 and in the figure, the Dow Jones Utility average annual growth was 5.5% through July 13, 2017 and 5.8% through July 18, 2019, California utility prices exceeded this average in all but one case, with Edison’s shares rising 9.4% per annum through the first date and 8.4% through this July, and Sempra growing 15.2% to the first date and even more at 15.3% to the latest. Even PG&E grew at almost twice the index rate at 10.4% in 2017, and then took an expected sharp decline with its bankruptcy.

Table 1

Cumulative Average Growth from January 2000 12/12/2012 7/13/2017 7/18/2019
Dow Jones Utilities 3.9% 5.5% 5.8%
Edison International 7.2% 9.4% 8.4%
PG&E Corp. 8.6% 10.4% 2.4%
Sempra 15.8% 15.2% 15.3%

The chart and table support three important findings:

  • California utility shares have significantly outpaced industry average returns since January 2000 and since March 2009;
  • California share prices only decreased significantly after the wildfire events that have been tied to specific market-perceived negligence on the part of the electric utilities in 2017 and 2018; and
  • Other events and state policy actions do not appear to have a measurable sustained impact on utilities’ valuations.

Not grasping the concept: PG&E misses the peak load shift

Utility peak shifted by solar graph

PG&E in its 2020 ERRA Forecast Proceeding testimony wrote “however, BTM DG [behind the meter distributed generation] has a limited impact to the annual system peak as customer-owned solar photovoltaic (PV) generation is minimal during the peak hour of 7 p.m.” Uh, how does PG&E know that customer-owned solar doesn’t contribute to reducing the system peak if PG&E does not meter that generation?

PG&E actually has it wrong. Customer-owned solar has in fact reduced the former pre-solar peak that used to occur between 2 and 4 p.m. The metered load that PG&E can see, which is customer usage minus solar output (BTM DG), has shifted its apparent peak from 4 p.m. to 7 p.m.–3 hours. The graphic above illustrates how this shift has occurred. (PG&E produced a similar chart of its 2016 loads in its TOU rate rulemaking.) So BTM DG has had a profound impact on the annual system peak.