Tag Archives: PG&E electricity rates

PG&E’s bankruptcy—what’s happened and what’s next?

The wildfires that erupted in Sonoma County the night of October 8, 2017 signaled a manifest change not just limited to how we must manage risks, but even to the finances of our basic utility services. Forest fires had been distant events that, while expanding in size over the last several decades, had not impacted where people lived and worked. Southern California had experienced several large-scale fires, and the Oakland fire in 1991 had raced through a large city, but no one was truly ready for what happened that night, including Pacific Gas and Electric. Which is why the company eventually declared bankruptcy.

PG&E had already been punished for its poor management of its natural gas pipeline system after an explosion killed nine in San Bruno in 2010. The company was convicted in federal court, fined $3 million and placed on supervised probation under a judge.

PG&E also has extensive transmission and distribution network with more than 100,000 miles of wires. Over a quarter of that network runs through areas with significant wildfire risk. PG&E already had been charged with starting several forest fires, including the Butte fire in 2015, and its vegetation management program had been called out as inadequate by the California Public Utilities Commission (CPUC) since the 1990s. The  CPUC caught PG&E diverting $495 million from maintenance spending to shareholders from 1992 to 1997; PG&E was fined $29 million. Meanwhile, two other utilities, Southern California Edison (SCE) and San Diego Gas and Electric (SDG&E) had instituted several management strategies to mitigate wildfire risk (not entirely successful), including turning off “line reclosers” during high winds to avoid short circuits on broken lines that can spark fires. PG&E resisted such steps.

On that October night, when 12 fires erupted, PG&E’s equipment contributed to starting 11 of those, and indirectly at least to other. Over 100,000 acres burned, destroying almost 9,000 buildings and killing 44 people. It was the most destructive fire in history, costing over $14 billion.

But PG&E’s problems were not over. The next year in November 2018, an even bigger fire in Butte County, the Camp fire, caused by a failure of a PG&E transmission line. That one burned over 150,000 acres, killing 85, destroying the community of Paradise and costing $16 billion plus. PG&E now faced legal liabilities of over $30 billion, which exceeds PG&E’s invested capital in its system. PG&E was potentially upside down financially.

The State of California had passed Assembly Bill 1054 that provided a fund of $21 billion to cover excess wildfire costs to utilities (including SCE and SDG&E), but it only covered fires after 2018. The Wine Country and Camp fires were not included, so PG&E faced the question of how to pay for these looming costs. Plus PG&E had an additional problem—federal Judge William Alsup supervising its parole stepped in claiming that these fires were a violation of its parole conditions. The CPUC also launched investigations into PG&E’s safety management and potential restructuring of the firm. PG&E faced legal and regulatory consequences on multiple fronts.

PG&E Corp, the holding company, filed for Chapter 11 bankruptcy on January 14, 2019. PG&E had learned from its 2001 bankruptcy proceeding for its utility company subsidiary that moving its legal and regulatory issues into the federal bankruptcy court gave the company much more control over its fate than being in multiple forums. Bankruptcy law afforded the company the ability to force regulators to increase rates to cover the costs authorized through the bankruptcy. And PG&E suffered no real consequences with the 2001 bankruptcy as share prices returned, and even exceeded, pre-filing levels.

As the case progressed, several proposals, some included in legislative bills, were made to take control of PG&E from its shareholders, through a cooperative, a state-owned utility, or splitting it among municipalities. Governor Gavin Newsom even called on Warren Buffet to buy out PG&E. Several localities, including San Francisco, made separate offers to buy their jurisdictions’ grid. The Governor and CPUC made certain demands of PG&E to restructure its management and board of directors, to which PG&E responded in part. PG&E changed its chief executive officer, and its current CEO, Bill Johnson, will resign on June 30. The Governor holds some leverage because he must certify that PG&E has complied by June 30, 2020 with the requirements of Assembly Bill 1054 that authorizes the wildfire cost relief fund for the utilities.

Meanwhile, PG&E implemented a quick fix to its wildfire risk with “public safety power shutoffs” (PSPS), with its first test in October 2019, which did not fare well. PG&E was accused of being excessive in the number of customers (over 800,000) and duration and failing to coordinate adequately with local governments. A subsequent PSPS event went more smoothly, but still had significant problems. PG&E says that such PSPS events will continue for the next decade until it has sufficiently “hardened” its system to mitigate the fire risk. Such mitigation includes putting power lines underground, changing system configuration and installing “microgrids” that can be isolated and self sufficient for short durations. That program likely will cost tens of billions of dollars, potentially increasing rates as much as 50 percent. One question will be who should pay—all ratepayers or those who are being protected in rural areas?

PG&E negotiated several pieces of a settlement, coming to agreements with hedge-fund investors, debt holders, insurance companies that pay for wildfire losses by residents and businesses, and fire victims. The victims are to be paid with a mix of cash and stock, with a face value of $13.5 billion; the victims are voting on whether to accept this agreement as this article is being written. Local governments will receive $1 billion, and insurance companies $11 billion, for a total of $24.5 billion in payouts.  PG&E has lined up $20 billion in outside financing to cover these costs. The total package is expected to raise $58 billion.

The CPUC voted May 28 to approve PG&E’s bankruptcy plan, along with a proposed fine of $2 billion. PG&E would not be able to recover the costs for the 2017 and 2018 fires from ratepayers under the proposed order. The Governor has signaled that he is likely to also approve PG&E’s plan before the June 30 deadline.

PG&E is still asking for significant rate increases to both underwrite the AB 1054 wildfire protection fund and to implement various wildfire mitigation efforts. PG&E has asked for a $900 million interim rate increase for wildfire management efforts and a settlement agreement in its 2020 general rate case calls for another $575 million annual ongoing increase (with larger amounts to be added in the next three years). These amount to a more than 10 percent increase in rates for the coming year, on top of other rate increases for other investments.

And PG&E still faces various legal difficulties. The utility pleaded guilty to 85 chargesof manslaughter in the Camp fire, making the company a two-time felon. The federal judge overseeing the San Bruno case has repeatedly found PG&E’s vegetation management program wanting over the last two years and is considering remedial actions.

Going forward, PG&E’s rates are likely to rise dramatically over the next five years to finance fixes to its system. Until that effort is effective, PSPS events will be widespread, maybe for a decade. On top of that is that electricity demand has dropped precipitously due to the coronavirus pandemic shelter in place orders, which is likely to translate into higher rates as costs are spread over a smaller amount of usage.

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.

CCAs don’t undermine their mission by taking a share of Diablo Canyon

Northern California community choice aggregators (CCAs) are considering whether to accept an offer from PG&E to allocate a proportionate share of its “large carbon-free” generation as a credit against the power charge indifference adjustment (PCIA) exit fee.  The allocation would include a share of Diablo Canyon power. The allocation for 2019 and 2020; an extension of this allocation is being discussed on the PCIA rulemaking.

The proposal faces opposition from anti-nuclear and local community activists who point to the policy adopted by many CCAs not to accept any nuclear power in their portfolios. However, this opposition is misguided for several reasons, some of which are discussed in this East Bay Community Energy staff report.

  • The CCAs already receive and pay for nuclear generation as part of the mix of “unspecified” power that the CCAs buy through the California Independent System Operator (CAISO). The entire cost of Diablo Canyon is included in the Total Portfolio Cost used to calculate the PCIA. The CCAs receive a “market value” credit against this generation, but the excess cost of recovering the investment in Diablo Canyon (for which PG&E is receiving double payment based on calculations I made in 1996) is recovered through the PCIA. The CCAs can either continue to pay for Diablo through the PCIA without receiving any direct benefits, or they can at least gain some benefits and potentially lower their overall costs. (CCAs need to be looking at their TOTAL generation costs, not just their individual portfolio, when resource planning.)
  • Diablo Canyon is already scheduled to close Unit 1 in 2024 and Unit 2 in 2025 after a contentious proceeding. This allocation is unlikely to change this decision as PG&E has said that the relicensed plant would cost in excess of $100 per megawatt-hour, well in excess of its going market value. I have written extensively here about how costly nuclear power has been and has yet to show that it can reduce those costs. Unless the situation changes significantly, Diablo Canyon will close then.
  • Given that Diablo is already scheduled for closure, the California Public Utilities Commission (CPUC) is unlikely to revisit this decision. But even so, a decision to either reopen A.16-08-006 or to open a new rulemaking or application would probably take close to a year, so the proceeding probably would not open until almost 2021. The actual proceeding would take up to a year, so now we are to 2022 before an actual decision. PG&E would have to take up to a year to plan the closure at that point, which then takes us to 2023. So at best the plant closes a year earlier than currently scheduled. In addition, PG&E still receives the full payments for its investments and there is likely no capital additions avoided by the early closure, so the cost savings would be minimal.

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?

 

 

 

 

PG&E apologizes, yet again

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(Image: ABC 7 News)

I listened to PG&E’s CEO Bill Johnson and his staff apologize for its mishandling of the public safety power shutoffs (PSPS) that affected over 700,000 “customers” (what other industry calls meters “customers”?) yesterday. And as I listened, I thought of the many times that PG&E has fumbled (or even acted maliciously) over the years. Here’s my partial list (and I’m leaving out the faux pas that I’ve experienced in regulatory proceedings):

  • Failing to turn off power locally in 2017 and 2018 under hazardous weather conditions, which led to the Wine Country and Camp fires.
  • Failing to install distribution shut off equipment that was installed by San Diego Gas & Electric and Southern California Edison after the 2007 wildfires in Southern  California.
  • Signing too many power purchase agreements with renewables in the 2009 to 2014 period that were for too long of terms (e.g., 20 years instead of 10 years). PG&E is unable to take advantage of the dramatic cost decreases created by California’s bold investments. For a comparison, PG&E’s renewable portfolio costs about 20% more than SCE’s. (I am one of a few that has access to the confidential portfolio data for both utilities.)
  • Failing to act on the opportunity to sell part of its overstuffed renewable portfolio to the CCAs that emerged from 2010 to 2016. Those sales could have benefited everyone by decreasing PG&E’s obligations and providing the CCAs with existing firm resources. That opportunity has now largely passed.
  • The gas pipeline explosion in San Bruno in 2010 caused by PG&E’s failure to keep proper records for decades. PG&E was convicted of a felony for its negligence.
  • Overinvesting in obsolete distribution infrastructure after 2009 by failing to recognize that electricity demand had flattened and that customers were switching en masse to solar rooftops. (I repeatedly filed testimony starting in 2010 pointing out this error.)
  • Deploying an Advanced Meter Infrastructure (AMI) system starting in 2004 using SmartMeters that claimed that it would provide much more control of PG&E’s distribution system, and deliver positive benefits to ratepayers. Savings have largely failed to materialize, and PG&E’s inability to use its AMI to more narrowly target its PSPS illustrates how AMI has failed to deliver.
  • Acquiring and building three unneeded natural gas plants starting in 2006. Several merchant-owned plants constructed in the early 2000s are already on the verge of retiring because of the flattening in demand.
  • Failing to act in May 2000 to end the “competitive transition” period of California’s restructuring by agreeing to the market valuation of its hydropower system.
  • If PG&E had ended the transition period, it would have been immediately free to sign longer term contracts with merchant generators, thereby taking away the incentive for those generators to manipulate the market. The subsequent energy crisis most likely would have not occurred, or been much more isolated to Southern California.
  • PG&E’s CEO in 1998 made a speech to the shareholders stating that it was PG&E’s intent to extend the transition period as far as possible, to March 2001 at least. (We cited this speech from a transcript in the 1999 GRC case.)
  • Offering rebuttal in the 1999 GRC that instead confirmed the ORA’s analysis that the optimal size of a utility is closer to 500,000 customers rather than 4 million plus. Commissioner Bilas wrote a draft decision confirming this finding, but restructuring derailed the vote on the case.
  • Being caught by the CPUC in diverting $495 million from maintenance spending to shareholders from 1992 to 1997. PG&E was fined $29 million.
  • Forcing the CPUC in 1996 to adopt the “competitive transition charge” which was tied to the fluctuating CAISO day-ahead market price instead of using Commissioner Knight’s up front pay out for stranded assets. The CTC led to the “transition period” which facilitated the ability of merchant generators to manipulate the market price.
  • Two settlement agreements allow PG&E to fully recover its costs in Diablo Canyon by January 1, 1998 based on its authorized rate of return from 1986 to 1998, but also allows it to put into ratebase about half of its “remaining” construction costs as a prelude to restructuring.
  • Getting caught in 1990 telling FERC that PG&E was short resources and needed to build more, while telling the CPUC that it had a long term surplus and that it needed to curtail its payments to third-party qualifying facilities (QF) generators.
  • In the early 1980s, failing to set up a rationale process for signing QF contracts that limited the addition of these resources. In addition, PG&E missed an important pricing calculation mistake in the capacity payment term that led to a double payment to QFs.
  • In the 1970s, making many construction management mistakes when building the Diablo Canyon nuclear power plant, including reversing the blueprints, that led to the costs rising from $315 million to over $5 billion. (And Diablo Canyon in 3 of the last 5 years has operated at a loss and should not have been generating for several months each of those years.)
  • In the 1960s, signing an agreement with Sacramento Municipal Utility District (SMUD) to finance the construction of the Rancho Seco nuclear plant that essentially gave SMUD free energy when Rancho Seco wasn’t generating. The result was the mismanagement of the plant, which was so damaged that it was closed in 1989 (in part as a result of analysis conducted by the consulting team that I was on.)

The other two California IOUs are guilty of some of these same errors, and SMUD and Los Angeles Department of Water and Power (LADWP) also do not have a clean bill of health, but the quantities and magnitudes to don’t match those of PG&E.

Why the CPUC has it wrong on the PCIA

Nick Chaset is the CEO of East Bay Community Energy which is a community choice aggregator (CCA) that serves Alameda County. He also was Commission President Michael Picker’s chief advisor until last year when he left for EBCE. He explains in this article how two proposed decisions that the CPUC is considering are fundamentally wrong and will shift cost onto CCA customers. (I testified on behalf of CalCCA in this proceeding. I’ll have more on this before the Commission’s scheduled vote October 11.)

Figure 1 – CPUC’s Proposed Resource Adequacy Value vs. True Market Values

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Figure 2 – GHG Premium Value Missing from CPUC Proposed Decision

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Figure 3 – Falling Utility Rates as Customers Depart Filed in Their ERRA Rate Applications

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Dunning gets it wrong again on VCE

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Valley Clean Energy Alliance (VCE) was in the Davis opinion columns this weekend again. First, Bob Dunning wrote another column in the Davis Enterprise that mischaracterizes the switch to VCE from PG&E as “mandated” and implies that local government didn’t trust Davis citizens to make the right choice. Then, David Greenwald wrote a column in the Davis Vanguard on how Dunning had ignored the authorization of the development and formation of VCE and is late to the game.

In both cases, the distinction between the choice to form VCE made by city councils and the Board of Supervisors after substantial study  is not distinguished from the choice that electricity ratepayers now have as to which entity will serve them. Previously, Yolo County ratepapers had no choice as to who should serve them–it took the formation of VCE to create that choice. If Dunning has a problem with that even offering that choice in the first place, then that’s a much more fundamental problem. But he is not being so transparent in his opposition, with is either disingenuous or ignorant.

I wrote the following email to Bob Dunning (I had an earlier letter to the editor already published in the Enterprise, that I also posted on this blog and the Davis Vanguard.)

You complain that somehow you’ve been “mandated” to sign up with Valley Clean Energy Authority. Yet you fail to ask the question “why was I mandated to sign up with PG&E all of those years?” Why does PG&E get a free pass from your scrutiny?

Instead now, you actually have a choice. We trust that you will make the right choice, whereas before you had NO choice. And you are not “mandated” to join VCE. You can act to switch to PG&E if you so choose. What has changed is the starting point of your choice. The default is no longer PG&E—it’s VCE. There’s nothing wrong with changing the default choice, but we have to start with a default since everyone wants to continue to receive electricity. (The other option is like they did with long distance service in the late 1980s with random assignment as the starting point, but that seems too much bother.)

 Send me your answers in your next column.

As to the Vanguard, I posted:

I think your column misses the fundamental point–contrary to everything that Dunning writes, we DO have a choice–it’s just that the starting point (default) isn’t what he wants. He prefers that the big corporations get the favored pole position.

 

Reaction to Is “Community Choice” Electric Supply a Solution or a Problem?

Severin Borenstein at the Energy Institute @ Haas wrote a good summary of the issues around community choice aggregation.

Source: Is “Community Choice” Electric Supply a Solution or a Problem?

I am on the City of Davis’ Community Choice Energy Advisory Committee and have been looking at these issues closely for a year. I had my own reactions to this post:

First, in California the existing and proposed CCEs (there are probably a dozen in process at the moment to add to the 3 existing ones) universally offer a higher “green” % product than the incumbent IOU, most often a 50% RPS product. And although MCE and SCP started out relying on RECs of various types to start out, they all are phasing out most of those by 2017. I think most will offer a 100% product as well.

The reason that these CCE’s are able to offer lower rates than the IOUs at a lower RPS is that the IOUs prematurely contracted long for renewables in anticipation of the 2020 goal. In fact, the penalty for failing to meet the RPS in any given year is so low, that the prudent strategy by an IOU would have been to risk being short in each year and contract for the year ahead instead of locking in too many 20+ year PPAs. At least one reason why this happened is that the IOUs require confidentiality by any reviewers and no connections to any competing procurement decisions. As a result the outside reviewers couldn’t be up to speed on the rapidly falling PPA prices. The CPUC has made a huge mistake on this point (and the CEC has rightfully harassed the CPUC over this policy.)

CCE’s also offer the ability to craft a broader range of rate offerings to customers–even flat 20 year rates that can compete with solar roofs on the main issue that customers really care about: price guarantees. In addition, CCE’s are more likely to be to nimbly adjust a rapidly changing utility landscape. CCE’s are much less likely to care about falling loads because their earnings aren’t dependent on continued service.

It’s also to recognize the difference between local government general services (e.g., safety and public protection, social services, regulation, etc.) and enterprise services (e.g., utilities of all sorts). In general, the latter are as efficient as IOUs (except LADWP which illustrates the INefficiency created by overlarge organizations). So one can’t make a broad generalization about local government problems and how they might apply in this situation. The fact is that almost all of the existing and new CCEs are or will be JPAs, which are often even leaner. (Lancaster is the exception.)

Finally, Severin made this statement:

“Whatever regulatory mandates, managerial mistakes, or incompetence occurred in the past, customers switching to a CCA should not be allowed to shift their share of costs from past decisions onto other ratepayers.”

I have to disagree to a certain exent with this statement. Am I forced to pay for the past incompetencies of GM or GE or any other corporation? Yes, utilities have a higher assurance of return on their investments, but no where is it written that it is “ironclad.” Those utilities had an assurance first as the sole legal provider and then as the provider of last resort, but that’s eroding. In California, the CTC was a political deal to get the IOUs out of the way. The fact is in California that the CPUC abrogated its responsibility to oversee these decisions on behalf of ratepayers with the encouragement of the IOUs. If the IOUs want to retain their customers, then they should be forced to compete with the CCEs (and DA LSEs.) It’s time to reopen this matter.

And to add a bit more:

The logic of this statement is that ANY customer who leaves the system, including moving to another area, state or nation, should have to continue to pay these stranded costs. Why should we draw the line arbitrarily at whether they happen to still get distribution services even though the generation services have been completely severed? Particularly if someone moves from say, San Francisco to Palo Alto, that customer still relies on PG&E’s transmission system and its hydro system for ancillary services. Why not charge that Palo Alto customer a non-by-passable charge? And why shouldn’t it be reciprocal? Relying on “political practicality” is not an answer. Either ALL customers are tethered forever, or no customers are required to meet this obligation.

 

Equity issues in TOU rate design

I attended the Center for Research into Regulated Industries (CRRI) Western Conference last week, which includes many of the economists working on various energy regulatory issues in California. A persistent theme was the interrelationship of time-varying rates (TVR) and development of distributed generation like rooftop solar. One session was even entitled “optimal rates.” We presented a paper on developing the proper perspectives and criteria in valuing distributed solar resources in another session. (More on that in another post.)

With the pending CPUC decision in the residential ratemaking rulemaking, due July 3, time of use rates (TOU) rates were at the top of everyone’s mind. (With PG&E violations of the ex parte rules, the utilities were cautious about who they were presenting with at least one Commission advisor attending. At least one presentation was scotched for that reason.) Various results were presented, and the need for different design elements urged on efficiency grounds. In the end though I was struck most by two equity issues that seem to have been overlooked.

First, various studies have shown that TOU rates deliver larger savings for customers who have various types of automated response equipment such as smart thermostats (e.g., NEST) or smart appliances. Those customers will see bigger bill savings and may find that doing so is more convenient and comfortable. An underlying premise in these studies is that the customer is the decision maker. But for 45% of California’s residents–renters–that is not the case. As a result tenants, who tend to have lower incomes, are likely to be subsidizing home owners who are better equipped to benefit from TOU rates.

Tenants must rely on landlords to make those necessary investments. Landlords don’t pay the bills or realize the direct savings in what is called the “split incentive” problem. And landlords may be concerned that future tenants might not like the commitments that come with the new smart devices. For example, signing up for PG&E’s SmartAC program can face this barrier.

So in considering residential customer impacts, the CPUC should address the likely differential in opportunities and benefits between owner-customers and tenant-customers. Solutions might include rate design differences, or moving toward a model where energy service providers (ESP or ESCo) take over appliance ownership in multifamily buildings. This split incentive is endemic across many programs such as the solar initiative and energy efficiency.

Second, a fixed charge have been proposed to address the anticipated impact of solar net energy metering. The majority of costs to be covered are for the “customer services” that run from the flnal line transformer to the meter. (I’ve been focused on this segment while representing the Western Manufactured Housing Communities Association (WMA) on master-metering issues.) However, the investments in customer services are not uniform across residences. For older homes, the services or “line extensions” may have already been paid off (e.g., most homes built before 1975), and with inflation, the costs for newer homes can be substantially higher.

The fixed charge would be based on one of two methods. In current rate cases, the new or “marginal” cost for a line extension is the starting point of the calculation, and usually the cost is scaled up from that. However, given the depreciation and inflation, the utilities will receive much more revenue than what they are entitled to under regulated returns. In the second method, the average cost for all services will be applied to all customers. This solves the problem of excess revenues for the utility, but it does not address the subsidies that flow from customers in older homes to those in newer ones. Because the residents of older homes tend to be tenants and have lower incomes, this again is a regressive distribution of costs. Solutions might include no fixed charge at all, differences in rates by house vintage, or discounts in the fixed charge as SMUD has instituted.

Regardless, these types of subsidies flow the wrong direction.

Davis to look at Community Choice Energy

After calling a halt to the deeper exploration of an electric publicly-owned utility, the city has turned to an easier mountain to climb in community choice energy aggregation (now remonikered to CCE). The original POU study briefly looked at the CCE option and moved past (and in my opinion used too generic of an approach to assess the POU path with some incorrect assumptions and didn’t consider the rapidly changing electricity market). Several direct access providers have approached the city and interested parties about helping implement a CCE. The citizen’s committee will look at whether a CCE opens up new value for the city and its citizens, and whether to go it alone or to join another CCE. Marin Clear Energy and Sonoma Clean Power both have participation rates over 90%. I will be sitting on that committee as an appointee via the Coalition for Local Power. (I also sit on the Utilities Rates Advisory Committee which has an appointee.)

Perhaps one of the most attractive features is that Davis can gain control of the energy efficiency funds available from the public good charge by preparing a plan specific to the city. Fortunately, the framework for that plan is already underway with a prompt from the Georgetown University Energy Prize.