Tag Archives: PG&E electricity rates

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.

 

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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.

PG&E to release 65,000 emails since 2010

PG&E in the wake of more revelations about ex parte contacts with CPUC commissioners and staff is releasing 65,000 emails over the period from 2010.  This should make for some interesting reading by interested parties. Is there anyone out their who might like to cooperatively compile a readable database?

Looking at a locality’s options as the energy marketplace changes

Here’s the first in a series of articles that I am coauthoring about how the new direction in the energy utilities marketplace can affect the choices for a locality like the City of Davis. This one is with Gerry Braun. This first article reviews the findings of study conducted last year that focused on a more traditional utility models, and then sketches the most salient options. This and future articles with other co authors will include:

  • What are the options going forward for Davis and what have we looked at.
  • Describing decentralized energy systems
  • How a decentralized energy system might fit into achieving local goals (e.g., climate action plan) and affect economic activity.
  • Barriers to achieving local goals in this future scenario.
  • Comparisons of potential business models to overcome those barriers.

Overwhelmed by “opportunities” at the CPUC

The opening of yet another rulemaking at the CPUC and the revelations of more contacts between PG&E and CPUC Commissioners are two sides of a larger conundrum in state electricity policy development and implementation. The OECD recently issued a wish list for how regulatory agencies should be structured and behave. (Thanks to Mark Pearson for posting this.) Yes, some are “pie in the sky” but they provide a useful means of evaluating how a regulatory agency is performing.

Looking at the first principle, the CPUC has been set adrift in part by the lack of role clarity in the state. At one point at least 8 statewide agencies had significant roles in electricity planning and ratemaking. (Along with the CPUC, there’s been the CEC, CAISO, CARB, CDWR, SWRCB, Electricity Oversight Board, and California Power Authority, the last 2 now defunct.) And there are additional local agencies (e.g., SCAQMD). This has blurred the lines of authority and allowed forum shopping.

And perhaps most importantly the number of proceedings at the CPUC have proliferated to a point where it is impossible for intervenors to devote enough resources to follow what’s happening everywhere. At least 14 different rulemakings are looking at interdependent elements of planning for increased renewables and the transformation of the electricity market. These include the long term power procurement, renewables portfolio standard, energy efficiency, water-energy nexus, demand side response, utility shareholder incentives, storage, distributed generation and self generationsolar initiative, net energy metering, alternative fueled and electric vehiclesresidential rate design, CCA rules, and recently, distribution resources planning.  And these don’t count the many utility applications such as the green tariff and community solar garden proposals. Some of these proceedings have been open over a decade with only partial resolution, and the CPUC has opened direct successors up to 4 times. While looking to develop a consistent regulatory framework for evaluating integrated demand side resources is an admirable goal, it could be overwhelmed by the divided attention demanded from all of these other proceedings. That undermines another OECD principle–transparency–even if appearances look differently.

Finally funding for both intervenors and skilled CPUC staff has become untenable and effective participation in declining, further eroding yet another OECD principle. This allows the well-funded utilities to influence outcomes while no one is looking. The documentation of the meetings and emails are only a reflection of the underlying problems.

The answers would seem to include:

  • to consolidate proceedings rather than opening new ones,
  • not adding yet more ratesetting proceedings for specific add ons, and
  • funding intervenors on a more equitable basis with utilities and paying those groups sooner than two years after the relevant decision.

Some of these will require legislative action; others might be implemented after the current CPUC president has left. But it will only happen if intervenors collectively demand reform.

Rethinking the rates that utilities offer to customers

I just got back from an annual conference put on by the Center for Research in Regulated Industries. It brings together many of the applied economists and policy analysts working in California’s electricity industry. I presented a paper on reconsidering rate design.

Customers are often left out of the conversation about how to move forward into the new energy future, as they were at the recent CAISO Symposium where not a single customer representative was included in the “Town Hall Meeting.” Current retail rate tariffs seem to be designed with little thought about how customers would prefer to pay for their energy, and what might best encourage consumer energy management. And when customers are asked to take on more risk or cost to address energy needs, their revenue responsibility is often unchanged.

How should utilities align their rates and tariffs to fit customers’ preferences? Utilities both face a rapidly evolving energy marketplace and have available to them a larger portfolio of technologies to provide more services and to measure usage across different dimensions. One important step that utilities could take is to offer customers the same variety of contracts as the utilities make with their suppliers, so that rates mirror the power market.

Customers have a range of preferences, and some prefer to be more innovative or risk takers than others. To better match the market, should utilities offer a range of tariffs, and even allow customers to construct a portfolio of rates that allow a mix of hedging strategies? How should the costs be allocated equitably to customers to reflect the varying risks in those portfolios? How should the benefits of lower costs be allocated between the active and passive customers? The new metering infrastructure also provides opportunities for different billing strategies.

How should time varying rate (TVR) periods be structured to adapt to the potential shift over time when peak meter loads occur? Should the periods be defined by utility-side resources or the combination with customer-side resources? Is the meter an arbitrary division for setting the price? What is the balance between rate stability to encourage customer investment versus matching changing system costs? Should the utilities offer different TVR periods depending on the desired incentives for customer response?
In developing costs, how should utilities and commissions consider how resources are added, and in what capacity? Renewables are now part of the incremental resources for “new” load, and we can no longer rely on the assumption that fossil fuels are the marginal resource 100% of the time.

The “super off-peak” rate offered by Southern California Edison (SCE) to agricultural customers is one example of how a rate can be constructed to encourage customer participation in autonomous ongoing energy management. Are the incentives appropriate for that rate? Over what term should these rates be set given customer investment?

If you’re interested in this paper, drop me a line and I’ll send it along.