Tag Archives: utility rates

David Mitchell in the LA Times: As drought drives prices higher, millions of Californians struggle to pay for water

Leave a reply

M.Cubed Partner David Mitchell was interviewed for an article on rising residential water rates in California in this October 24 article:

Across the state, water utility prices are escalating faster than other “big ticket” items such as college tuition or medical costs, according to David Mitchell, an economist specializing in water.

“Cost containment is going to become an important issue for the sector in the coming years” as climate change worsens drought and water scarcity, he said.

The price of water on the Nasdaq Veles California Water Index, which is used primarily for agriculture, hit $1,028.86 for an acre-foot on Oct. 20 — a roughly 40% increase since the start of the year. An acre-foot of water, or approximately 326,000 gallons, is enough to supply three Southern California households for a year.

Mitchell said there are short- and long-term factors contributing to rising water costs.

Long-term factors include the replacement of aging infrastructure, new treatment standards, and investments in insurance, projects and storage as hedges against drought.

In the short term, however, drought restrictions play a significant role. When water use drops, urban water utilities — which mostly have fixed costs — earn less revenue. They adjust their rates to recover that revenue, either during or after the drought.

“So it’s not right now a pretty picture,” Mitchell said.

David Mitchell’s practice areas include benefit-cost analysis, regional economic impact assessment, utility rate setting and financial planning, and natural resource valuation. Mr. Mitchell has in-depth knowledge of the water supply, water quality and environmental management challenges confronting natural resource management agencies.

Profound proposals in SCE’s rate case

1 Reply

A catastrophic crisis calls for radical solutions that are considered out of the box. This includes asking utility shareholders to share in the the same pain as their customers.

M.Cubed is testifying on Southern California Edison’s 2021 General Rate Case (GRC) on behalf of the Small Business Utility Advocates. Small businesses represent nearly half of California’s economy. A recent survey shows that more than 40% of such firms are closed or will close in the near future. While these businesses struggle, the utilities currently assured a steady income, and SCE is asking for a 20% revenue requirement increase on top already high rates.

In this context, SBUA filed M.Cubed’s testimony on May 5 recommending that the California Public Utilities Commission take the following actions in response to SCE’s application related to commercial customers:

  • Order SCE to withdraw its present application and refile it with updated forecasts (that were filed last August) and assumptions that better fit the changed circumstances caused by the ongoing Covid-19 crisis.
  • Request that California issue a Rate Revenue Reduction bond that can be used to reduce SCE’s rates by 10%. The state did this in 1996 in anticipation of restructuring, and again in 2001 after the energy crisis.
  • Freeze all but essential utility investment. Much of SCE’s proposed increase is for “load growth” that has not materialized in the past, and even less likely now.
  • Require shareholders, rather than ratepayers, to bear the risks of underutilized or cost-ineffective investments.
  • Reduce Edison’s authorized rate-of-return by an amount proportionate to its lower sales until load levels and characteristics return to 2019 levels or demonstrably reach local demand levels at the circuit or substation that justify requested investment as “used and useful.”
  • Enact Covid-19 Commercial Class Economic Develop (ED) and Supply Chain Repatriation rates. These rates should be at least partially funded in part by SCE shareholders.
  • Order Edison to prioritize deployment of beneficial, flexible, distributed energy resources (DER) in-lieu of fixed distribution investments within its grid modernization program. SCE should not be throwing up barriers to this transformation.
  • Order Edison to reconcile its load forecasts for its local “adjustments” with its overall system forecast to avoid systemic over-forecasting, which leads to investment in excess distribution capacity.
  • Order SCE to revise and refile its distribution investment plan to align its load growth planning with the CPUC-adopted load forecasts for resource planning and to shift more funds to the grid modernization functions that focus on facilitating DER deployment specified in SCE’s application.
  • Order an audit of SCE’s spending in other categories to determine if the activities are justified and appropriate cost controls are in place.  A comparison of authorized and actual 2019 capital expenditures found divergences as large as 65% from forecasted spending. The pattern shows that SCE appears to just spend up to its total authorized amount and then justify its spending after the fact.

M.Cubed goes into greater depth on the rationale for each of these recommendations. The CPUC does not offer many forums for these types of proposals, so SBUA has taken the opportunity offered by SCE’s overall revenue requirement request to plunge in.

(image: Steve Cicala, U. of Chicago)

Victory for mobilehome park residents and owners

1 Reply

The California Public Utilities Commission (CPUC) authorized the continuance for the next 10 years of the program that converts ownership of privately-held utility systems in mobilehome parks to that of investor-owned energy utilities, including Pacific Gas & Electric, Southern California Edison, San Diego Gas and Electric and Southern California Gas. Of the 400,000 mobilehome spaces in California, over 300,000 are currently served by “master metered” systems that are owned and maintained by the park owner.

Most of these systems were built more than 40 years ago, although many have been replaced periodically. This program aims to transfer all of these systems to standard utility service. Due to the age of these systems, some engineered to only last a dozen years initially because these parks were intended as “transitional” land uses, concerns about safety have been paramount. This program will bring these systems up to the standards of other California ratepayers.

Along with improved safety, residents will gain greater access to energy efficiency and other energy management programs that they already fund at the utilities, and smoother billing. Residents also will have access to time of use rates that has been precluded by the intervening master meter. Park owners will avoid the increasing complexity of billing, system maintenance and safety inspections and filings, and future costs of system replacement. In addition, park owners have been inadequately compensated through utility rates for maintaining those systems, and have resistance in recovering related costs through rents.

I have been working with one of my clients, Western Manufactured Housing Communities Association (WMA) since 1997 to achieve this goal. The momentum finally shifted in 2014 when we convinced the utilities that making these investments could be profitable. First athree-year pilot program was authorized, and this recent decision builds on that.

 

Davis Should Set Its Utility Reserve Targets with a Transparent and Rigorous Method

Leave a reply

The City of Davis Utilities Commission is considering on February 19 whether to disregard the preliminary recommendations of the Commission’s Enterprise Fund Reserve Policies subcommittee to establish a transparent, relatively rigorous and consistent method for setting City reserves. The Staff Report, written by the now-departed finance director, ignored the stated objectives of both the Utilities and Finance and Budget Commissions to develop a consistent set of policies that did not rely on the undocumented and opaque practices of other communities. Those practices had no linkage whatsoever to risk assessment, and the American Water Works Association’s report that the Staff relied on again to reject the Commission’s recommendation again fails to provide any documentation on how the proposed targets reflect risk mitigation—they are simply drawn from past practices.[1]

The City’s Finance & Budget Committee raised the question of whether the City held too much in reserves over five years ago, and the Utilities Commission agreed in 2017 to evaluate the status of the reserves for the four City enterprise funds—water, sanitation/waste disposal, sewer/wastewater, and stormwater. A Utilities Commission subcommittee reviewed the current reserve policies and what is being done by other cities. (I was on that subcommittee.) First, the subcommittee found that the City was using different methods for each fund, and that other cities had not conducted risk analyses to set their targets either. The subcommittee conducted a statistical analysis that allows the City to adjust its reserve targets for changing conditions rather than just relying on the heuristic values provided by consultants.

The subcommittee’s proposal adopted initially by the Utilities Commission achieved three objectives that had been missing from the previous informal reserves policy. Two of these would still be missing under the Staff’s proposal:

  1. Clearly defining and documenting the reserves held for debt coverage. While these amounts were shown in previous rate studies, the documented source of those amounts generally not included and the subcommittee’s requests brought those to the fore. The Staff method appears to accept continuance of that practice. The Staff proposes to keep those separate, which differs from past practice which rolled all reserves together.
  2. Reserve targets are first set based on the historic volatility of enterprise net income. In other words, the reserves would be determined transparently with a rigorous method on the basis of the need for those reserves. The method uses a target that is statistically beyond the 99th percentile in the probability distribution. And this target can be readily updated for new information each year. The Staff report rejects this method to adopt a target that refers to the practice of other communities, and none of those practices appear to be based on analytic methods from research done by the subcommittee.
  3. Reserve targets are then adjusted to cover the largest single year capital improvement/replacement investment made historically to ensure enough cash for non-debt expenditures. Because the net income volatility is a joint function of revenues, operating expenditures and non-debt capital expenditures, the latter category is not separated out of the analysis. However, an added margin can be incorporated. That said, the data set for the fiscal years of 2008/2009 to 2016/2017 used by the subcommittee found that setting the target based on the volatility has been sufficient to date. The Staff report appears to call for a separate, unnecessary reserve fund for this purpose based on annual depreciation that has no relationship to risk exposure, and implicitly duplicates the debt payments already being made on these utility systems. This would be a wasteful duplication that sets the reserves too high.

The Finance and Budget raised at least two important issues in its review:

  1. Water and sewer usage and revenues may be correlated so that the reserves may be shared between the two funds. However, further review shows that the funds have a slight negative correlation, indicating that the reserves should be held separately.
  2. The water fund already has an implicit reserve source when a drought emergency is declared because a surcharge of 25% is added to water utility charges. I agree that this should be accounted for in the historic volatility analysis. This reduces the volatility in fiscal years 2014/2015 and 2015/2016, and reduces the water fund volatility reserve from 26% to 21%.
  3. Working cash reserves are unnecessary because the utility funds are already well established (not needing a start up reserve), and that the volatility reserves already cover any significant lags in the revenues that may occur. This observation is valid, and I agree that the working cash reserves are duplicative of the other reserve requirements. The working cash reserves should be eliminated from the reserve targets for this reason.

Finally, the Staff proposal raises an issue about the appropriate basis for determining the sanitation/waste removal reserve target. The Staff proposes to base it solely on direct City expenses. However, the enterprise fund balance shows a deficit that includes the revenues and expenses incurred by the contractor, first Davis Waste Removal and then Recology. We need more specificity on which party is bearing the risk of these shortfalls before determining the appropriate reserve target. Given the current City accounting stance that incorporates those shortfalls, I propose using the Utility Commission’s proposed method for now.

Based the analysis done by Utilities Commission subcommittee and the recommendations of the Finance & Budget Committee, the chart above shows the target % reserves for each fund without the debt coverage target. It also shows the % reserve targets implied by the Staff’s proposed method.[2] The chart also shows corresponding dollar amount for the proposed total target reserves, including the debt reserves, and the cash assets held for those funds in fiscal year 2016/2017. Importantly, this new reserve target shows that the City held about $30 million of excess reserves in 2016/2017.

[1] It appears the Staff may have misread the Utilities Commission’s recommendation memorandum and confused the proposed targets policies with the inferred existing policies. This makes it uncertain as to whether the Staff fully considered what had been proposed by the Utilities Commission.

[2] The amounts shown in the October 16, 2019 Staff Report on Item 6B do not appear to be consistent with the methodology shown in Table 1 of that report.

Non-Profit Utilities Could Cure What Ails California Electricity

5 Replies

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.

A transparent municipal utility’s reserve target

1 Reply

Reserves chart

As one of my civic activities, I sat on the City of Davis Utility Rates Advisory Commission. In my final action with that commission, along with Elaine Roberts-Musser and Lorenzo Kristov, we prepared what might be a first-of-its kind enterprise fund reserve policy for the four utilities managed by the city. Up to this point, the URAC had been presented with rates development reports that appeared to use somewhat arbitrary, and inconsistent, methods of setting reserve targets. The city also appeared to be holding tens of millions of dollars in those funds that might be unneeded to meet expected reserve requirements.

With the City Council’s approval and support from the staff and the Finance and Budget Commission, we identified the elements that needed to be covered by reserves, including working capital, debt covenants, unanticipated capital replacements, and revenue-expense volatility. The first two elements were fairly straightforward to calculate, and unanticipated replacements didn’t appear to be significant. It was the analysis of the relationship of revenue and expense volatility where the report innovates. Previous studies had used some variation of a percentage of capital assets with no underlying explanation. Our solution was to derive an estimate of the outerbound of an annual revenue shortfall for a utility as buffer to allow rate or management adjustments.

In the end, the target reserves generally didn’t change much, but the City now has a transparent target that it can use to determine when it has excess funds that might be used in different fashions instead.

Commentary on CPUC Rate Design Workshop

Leave a reply

cartoon

The California Public Utilities Commission (CPUC) held a two-day workshop on rate design principles for commercial and industrial customers. To the the extent possible, rates are designed in California to reflect the temporal changes in underlying costs–the “marginal costs” of power production and delivery.

Professor Severin Borenstein’s opening presentation doesn’t discuss a very important aspect of marginal costs that we have too long ignored in rate making. That’s the issue of “putty/clay” differences. This is an issue of temporal consistency in marginal cost calculation. The “putty” costs are those short term costs of operating the existing infrastructure. The “clay” costs are those of adding infrastructure which are longer term costs. Sometimes the operational costs can be substitutes for infrastructure. However we are now adding infrastructure (clay) in renewables have have negligible operating (putty) costs. The issue we now face is how to transition from focusing on putty to clay costs as the appropriate marginal cost signals.

Carl Linvill from the Regulatory Assistance Project (RAP) made a contrasting presentation that incorporated those differences in temporal perspectives for marginal costs.

Another issue raised by Doug Ledbetter of Opterra is that customers require certainty as well as expected returns to invest in energy-saving projects. We can have certainty for customers if the utilities vintage/grandfather rates and/or structures at the time they make the investment. Then rates / structures for other customers can vary and reflect the benefits that were created by those customers making investments.

Jamie Fine of EDF emphasized that rate design needs to focus on what is actionable by customers more so than on a best reflection of underlying costs. As an intervenor group representative, we are constantly having this discussion with utilities. Often when we make a suggestion about easing customer acceptance, they say “we didn’t think of that,” but then just move along with their original plan. The rise of DERs and CCAs are in part a response to that tone-deaf approach by the incumbent utilities.

Enlisting Davis’ Citizen-Analysts | Davis Vanguard

Leave a reply

By Richard McCann

Why are we not using Davis’ wealth of human capital to our advantage? Why don’t we assign, and even hire or retain, these individuals to prepare these analyses for commission review?

Source: Enlisting Davis’ Citizen-Analysts | Davis Vanguard

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.

 

Thinking outside the box on the CPUC’s future

4 Replies

3peev_t658

Assemblymember Mike Gato (D-LA) is proposing a constitutional amendment to dissolve the CPUC–blowing up the box! The CPUC currently regulates energy utilities, telcom, transportation and water. That’s a tall order to ask five people to competently understand all of those arenas. And on the flip side, many have recognized that the state has too many “cooks in the kitchen” regulating energy, and it’s only gotten worse with increased climate change regulation. The CPUC hasn’t done much to burnish its reputation with the scandal of Mike Peevey’s “rulings for sale” and the inadequate responses to the San Bruno and Porter Ranch disasters. Closing up shop and starting over may be the best solution.