Tag Archives: regulation

PG&E hijacks its own website

PG&E PSPS website clip

I was looking for PG&E’s 2019 Catastrophic Events Memo Account (CEMA) on its website at https://www.pge.com/en_US/about-pge/company-information/regulation/regulation.page, and instead I was redirected to PG&E’s PSPS website at https://www.pgealerts.com/. It does not appear possible to get around this website to the regulatory filings that PG&E maintains on its website.

I guess that’s one way to get enough bandwidth after crashing its website during the PSPS blackouts.

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.

Not so bad in our estimate…

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The University of California ARE Update published a short study that found that the drought emergency regulations adopted by the State Water Resources Control Board were only 18% more costly than the most “efficient” standards. In May 2015, the State Water Resources Control Board adopted Resolution No. 2015-0032 which imposed restrictions to reduce water use by local agencies by 4 to 36 percent depending on their circumstances. Northern California agencies were to reduce usage by 16.2 percent on average, while Southern California utilities were to reduce by 22.5 percent. In the end, Northern California utilities far exceeded their target with a 23.3 percent reduction, and Southern California’s just missed theirs with an average of 21.4 percent. M.Cubed conducted the economic study of the regulations, and found that the insurance benefits were likely substantial enough to justify the costs.

The real headline of the study should be “Drought regulations remarkably efficient!” Given that the regulations were developed in just a few months and that they were done on a prospective basis with uncertainties and unknowns (e.g., the price elasticities referenced in the study), missing the mark by only 18% is truly remarkable. In comparison, the California Air Resources Board may have missed the mark by more than 100% in setting out its AB 32 Greenhouse Gas Reduction Scoping Plan in 2008 by relying too heavily on mandated measures such as renewables generation and certain types of energy efficiencies instead of more effective market based measures.

Nevertheless, the study appears to the make mistake of making the classic economist’s joke “sure it works in practice, but does it work in theory?” Consumers are chastised for behavior that doesn’t fit the fitted values for price elasticities. The study compares the mandated and achieved reductions and notes that achieved reductions were more even across agencies than the mandates. Agencies with lower mandates achieved higher reductions, and those with higher mandates fell short on achievements. Instead of questioning the original price elasticity estimates–and such estimates commonly have a wide range and are often situation specific–the report just plows ahead as though these theoretical results should have driven human behavior.

The more interesting question the researchers should have asked given the consistent patterns in achieved versus mandated reductions is what factors caused these agencies to diverge from the mandates. Geography is clearly only part of the reason. It also appears that there is not as much “demand hardening” at the low end of use, and a higher premium put on water uses at the upper end. These factors have implications for how we should modify our price elasticity estimates.

When is $100 billion not that big?

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When it’s measured against $18,675 billion ($18.7 trillion) produced by the U.S. economy. The Heritage Foundation issued a report claiming the Obama Administration imposed $107 billion in new burdens over seven years. That sounds like a huge amount, but that’s only 0.6% (six-tenths of a percent) of the economy. And that’s spread over seven years which means that this the reduction in the GDP growth rate was only 0.08% (eight hundredths of a percent) per year. Against an annual average growth rate of over 2%, that’s a trivial amount. Another way to think of it is this way: if you had a dinner bill from Applebee’s for $19, would you not by dinner it if cost a dime more? Probably not–you wouldn’t even notice.

Plus, the HF’s estimate ignores the benefits of those regulations. This graphic from the OMB that shows the estimated relative benefits to costs of regulation.

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I won’t dig too deeply into the Heritage Foundation’s analysis other than to make a couple of notes about about alternative perspectives that I am familiar with:

  • Heritage Foundation claims that the Clean Power Plan has cost $7.2 billion as the single largest increment. Yet Lawrence Berkeley National Laboratory (which is much better qualified on this issue than the HF) just released a study showing the net financial “costs” of the various renewable portfolio standard (RPS) requirements is actually a benefit $47 to $109 billion. (And that ignores the environmental benefits identified in the report.)
  • After the 2008 financial debacle, the industry was going to face increased regulation to reign in its behavior during the previous decade. So increased regulation under Dodd-Frank is to be expected. And the better question might be what is the drag on the economy from high financial-related transaction costs? One study found that transaction costs may be as high at 45% in the U.S. economy. The financial and legal sectors likely are a bigger drag than government regulation.
  • On FCC net neutrality, see a previous post about how bigger corporations and economic concentration reduces innovation, which leads to reduced growth. Net neutrality is intended to fight that concentration.

Big Business Is Killing Innovation in the U.S. – The Atlantic

How big business and overconcentration jams the wheels of innovation in the U.S. This is particularly relevant to encouraging new distributed energy resources on the electric utility grid–the poster child for monopolies.

Source: Big Business Is Killing Innovation in the U.S. – The Atlantic

What lessons should we take from the last wave of California utility reform?

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We’re now in the midst of the “third wave” of electricity industry reform in California. The first was in the early 1980s with the rise of independently-owned cogeneration and renewable resources. Mixed with increased energy efficiency, that led to a surplus of power in the late 1990s, which in turn created the push for restructuring and deregulation. Unfortunately, poorly designed markets and other factors precipitated the 2000-01 energy crisis. The rise of renewables and distributed resources is pushing a third wave that may change the industry even more fundamentally.

I wrote a paper in 2002 on how I viewed the history of California’s electricity industry through 2001 and presented this at a conference. (It hasn’t yet been published.) I identify some different factors for why the energy crisis erupted, and what lessons we might learn for this next wave.

 

Four articles on uncertainty and unconventional economics

From the current issue of American Economics Review:

Robust Social Decisions: We propose and operationalize normative principles to guide social decisions when individuals potentially have imprecise and heterogeneous beliefs, in addition to conflicting tastes or interests. To do so, we adapt the standard Pareto principle to those preference comparisons that are robust to belief imprecision and characterize social preferences that respect this robust principle. [This paper focused on decisions related to climate change.]

Beyond GDP? Welfare across Countries and Time: We propose a summary statistic for the economic well-being of people in a country. Our measure incorporates consumption, leisure, mortality, and inequality, first for a narrow set of countries using detailed micro data, and then more broadly using multi-country datasets. While welfare is highly correlated with GDP per capita, deviations are often large. Western Europe looks considerably closer to the United States, emerging Asia has not caught up as much, and many developing countries are further behind. Each component we introduce plays a significant role in accounting for these differences, with mortality being most important.

(W)hat proportion of consumption in the United States, given the US values of leisure, mortality, and inequality, would deliver the same expected utility as the values in France? In our results, lower mortality, lower inequality, and higher leisure each add roughly 10 percentage points to French welfare in terms of equivalent consumption. Rather than looking like 60 percent of the US value, as it does based solely in consumption, France ends up with consumption-equivalent welfare equal to 92 percent of that in the United States.

A summary:

(i) GDP per person is an informative indicator of welfare across a broad range of countries: the two measures have a correlation of 0.98. Nevertheless, there are economically important differences between GDP per person and consumption-equivalent welfare. Across our 13 countries, the median deviation is around 35 percent—so disparities like we see in France are quite common.

(ii) Average Western European living standards appear much closer to those in the United States (around 85 percent for welfare versus 67 percent for income) when we take into account Europe’s longer life expectancy, additional leisure time, and lower inequality.

(iii) Most developing countries—including much of sub-Saharan Africa, Latin America, southern Asia, and China—are substantially poorer than incomes suggest because of a combination of shorter lives and extreme inequality. Lower life expectancy reduces welfare by 15 to 50 percent in the developing countries we examine. Combined with the previous finding, the upshot is that, across countries, welfare inequality appears even greater than income inequality.

(iv) Growth rates are typically revised upward, with welfare growth averaging 3.1 percent between the 1980s and the mid-2000s versus income growth of 2.1 percent. A boost from rising life expectancy of more than a percentage point shows up throughout the world, with the notable exception of sub-Saharan Africa. When welfare grows 3 percent instead of 2 percent per year, living standards double in 24 years instead of 36 years; over a century, this leads to a 20-fold increase rather than a 7-fold increase.

Bailouts, Time Inconsistency, and Optimal Regulation: A Macroeconomic View:  A common view is that bailouts of firms by governments are needed to cure inefficiencies in private markets. We propose an alternative view: even when private markets are efficient, costly bankruptcies will occur and benevolent governments without commitment will
bail out firms to avoid bankruptcy costs. Bailouts then introduce inefficiencies where none had existed. Although granting the government orderly resolution powers which allow it to rewrite private contracts improves on bailout outcomes, regulating leverage and taxing size is needed to achieve the relevant constrained efficient outcome, the sustainably efficient outcome.

Long-Run Risk Is the Worst-Case Scenario: We study an investor who is unsure of the dynamics of the economy. Not only are parameters unknown, but the investor does not even know what order model to estimate. She estimates her consumption process nonparametrically…and prices assets using a pessimistic model that minimizes lifetime utility subject to a constraint on statistical plausibility…[A] way of interpreting our results is that they say that what people fear most, and what makes them averse to investing in equities, is that growth rates or asset returns are going to be persistently lower over the rest of their lives than they have been on average in the past.