Tag Archives: utility rates

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.

Three key steps in designing rates for solar power

KQED posted a good summary of how solar power is driving the residential rate design rulemaking at the CPUC. (M.Cubed works for EDF there.) I offer three steps that should be taken to address the issues of how to change ratemaking for a changing energy marketplace:

1) Consumers should see time varying prices (time of use or TOU being among that menu). Tiered rates make it impossible to see the current price for consumption, and tiered rates have been shown not to induce any additional conservation across the customer base. Consumer surveys show that customers want more control over their electricity use and the price signals to direct them.

2) Consumers should be offered a meaningful menu of rate options. This means rates that differ in risk exposure both over time of day and time horizon. Customers should be able to hedge against peak day prices or participate in demand response. They should be able to accept changes in hourly prices or buy a multi-year contract. Utilities already offer these contract options to their suppliers; why not treat their customers as they they are valued?

3) Any calculation of grid costs and responsibility should reflect the changing demand by consumers. The grid charges proposed by the utilities assume that future consumers will install the same-sized equipment as they do today and that they will consume in the same pattern. Solar panels are ready today to “island” a home from the network, and EV charging could create greater load diversity even at the circuit level. That will radically change utility investment. The distribution planning rulemaking is an important step toward resolving that issue but the CPUC hasn’t yet linked the proceedings.

Only the first issue is being addressed head on in the rulemaking and it hasn’t really delved into the importance of emerging consumer choice.

Reexamining growth and risk sharing for utilities

Severin Borenstein at the Energy Institute at Haas blogged about the debate over moving to residential fixed charges, and it has started a lively discussion. I added my comment on the issue, which I repost here.

The question of recovery of “fixed” costs through a fixed monthly charge raises a more fundamental question: Should we revisit the question of whether utilities should be at risk for recovery of their investments? As is stands now if a utility overinvests in local distribution it faces almost no risk in recovering those costs. As we’ve seen recently demand has trended well below forecasts since 2006 and there’s no indication that the trend will reverse soon. I’ve testified in both the PG&E and SCE rate cases about how this has led to substantial stranded capacity. Up to now the utilities have done little to correct their investment forecasting methods and continue to ask for authority to make substantial “traditional” investment. Shareholders suffer few consequences from having too much distribution investment–this creates a one-sided incentive and it’s no surprise that they add yet more poles and wire. Imposing a fixed charge instead of including it as a variable charge only reinforces that incentive. At least a variable charge gives them some incentive to avoid a mismatch of revenues and costs in the short run, and they need to think about price effects in the long run. But that’s not perfect.

When demand was always growing, the issue of risk-sharing seemed secondary, but now it should be moving front and center. This will only become more salient as we move towards ZNE buildings. What mechanism can we give the utilities so that they more properly balance their investment decisions? Is it time to reconsider the model of transferring risk from shareholders to ratepayers? What are the business models that might best align utility incentives with where we want to go?

The lesson of the last three decades has been that moving away from direct regulation and providing other outside incentives has been more effective. Probably the biggest single innovation that has been most effective has been imposing more risk on the providers in the market.

California has devoted as many resources as any state to trying to get the regulatory structure right–and to most of its participants, it’s not working at the moment. Thus the discussion of whether fixed charges are appropriate need to be in the context of what is the appropriate risk sharing that utility shareholders should bear.

This is not a one-side discussion about how groups of ratepayers should share the relative risk among themselves for the total utility revenue requirement. That’s exactly the argument that the utilities want us to have. We need to move the argument to the larger question of how should the revenue requirement risk be shared between ratepayers and shareholders. The answer to that question then informs us about what portion of the costs might be considered unavoidable revenue responsibility for the ratepayers (or billpayers as I recently heard at the CAISO Symposium) and what portion shareholders will need to work at recovering in the future. As such the discussion has two sides to it now and revenue requirements aren’t a simple given handed down from on high.

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.

Guest Post: The importance of engaging electricity consumers

My partner at M.Cubed Steven Moss wrote this editorial for The Potrero View on how we need to engage consumers when developing a vision of how the electricity future might evolve:

Multiple corporate monopolies have emerged, thrived, and withered over the last hundred years. Railroads, telegram and telephone services, air transportation, network television and newspapers all had highly lucrative heydays, but were ultimately cut down to size by a combination of government anti-trust activities and new technologies. Today there’s a plethora of transportation, communication, information, and entertainment services, most offered at lower cost or with greater value than what was on the former cartels’ menu.
The societal conversation continues over how to best manage quasi-monopolies, like cable and Internet services. Water utilities are struggling with how to pay for themselves in an era in which reducing consumption is essential to addressing chronic scarcity. But the monopoly sector most ripe for rapid change is the almost a half-trillion dollar electricity sector.
Throughout the U.S. electricity is provided by a mix of municipal, cooperative, and investor-owned utilities (IOUs), each with a lock on delivering large aspects of the service in their home territories. In California the three large IOUs — San Diego Gas and Electric, Southern California Edison, and Pacific Gas and Electric (PG&E) — have carved up the lion’s share of the state’s monopoly electricity market. All of them face a business model that’s been buffeted by the rapid policy-driven onsite of renewables and the emergence of other technologies that aren’t as dependent on a large, capital-intensive spoke — fossil fuel or nuclear power plant — and wheels — transmission and distribution — system to operate.
Today, a home or business can install devices to capture sunshine or wind and cope with intermittent power flows by managing the timing of their energy consumption and installing a storage device, which could include harnessing the battery in the electric vehicle parked in the garage. These types of systems may work best when they’re combined at the multiple-neighborhood level, to create a portfolio of resources that can reduce the risk that the failure of one device will have catastrophic outage consequences. The optimal size for a next generation grid may be roughly half the size of San Francisco, a back-to-the-future system that mirrors the more than 100 small service providers that combined more than a century ago to create PG&E.
Institutional change is tricky, though, when it comes to electricity. Although rates are high in California, outside the Central Valley in the summer, household bills are generally modest as a result of the state’s mild climate. There’s solid service reliability, with the IOUs generally doing a fine job restoring post-storm outages. And, thanks to public policies, low-income families are provided substantial subsidies, while the grid has grown increasingly green. Outside San Francisco — and post natural gas-disaster San Bruno — where tilting at PG&E is an ideological battle rather than an economic one, these characteristics serve to mute the potential for widespread ratepayer revolt, and encourage consumer advocacy groups to protect the existing monopoly system.
Yet without change, electricity service is poised to get much more expensive, and probably less green. Renewable intermittency — production drops when the sun doesn’t shine — doesn’t match with the current system, creating gaps that could be plugged by costly and polluting fossil fuel power plants, eroding much of the environmental gains achieved over the past decade. Despite substantial technological innovation which should spur price competition, utility rates are consistently rising, in part because two competing paradigms — New Age renewables, and Industrial Age fossil fuels — are being simultaneously pursued for political reasons.
The seeds of a solution are in creating more knowledge. Consumers are almost entirely ignorant of how the timing of their electricity use influences costs. Electricity rates don’t reflect the underlying expense — to the environment or grid — of providing service in a given time and place. Since price-based feedback to the IOUs is significantly muted, the monopolies operate as if demand is largely immune to change, and must be met by increasing amounts of generation to ensure reliability.
The pathways we take as the grid wobbles in the face of renewable disruption will determine how much we pay, out of our pockets, and through dirtier air, for the next few decades. Fortunately, there’s a ready way to remold the monopoly electric utility industry: get the prices right. If rates reflected the true costs of service — including greenhouse gas and polluting air emissions — consumers and businesses would take action to change their consumption patterns, aided by high technology companies eager to solve profitable problems. The Internet of Things would become the Energy System of Things, with renewables, storage, and a host of communicating devices connected to optimize energy use in an environmental sustainable way.
Offering transparent electricity prices won’t solve all of the grid’s challenges. But not doing so walls off essential innovation. Renewables and emerging technologies, combined with clever tariffs, could help ensure that California never builds another fossil fuel power plant. The state can protect low-income households from onerous electricity bills, by directly paying for energy efficiency investments, or providing bill credits. A small is beautiful ethos can emerge to rival the large, reliable, monopolies in providing high-quality services. If we get the prices right.

Repost: California Dream – How Big Data Can Fight Climate Change in Los Angeles

EDF and UCLA have created an interesting visual presentation on the potential for solar power and energy savings in the LA county, overlaid with socio-economic characteristics. (But I have some trouble with the representation of a few West LA communities as disadvantaged with high health risk–is that the UCLA campus?

Repost: Millennials and the Future of Electric Utilities

An insightful discussion about the new type of consumers that utilities will be facing–consumers who now expect to have customized experiences for no added cost.

One potential diversion though: The Brookings Institute description of Millenials–socially conscious, distrust of big companies, more favorable to government regulation–was used to describe the Baby Boomers 50 years ago. The actual changes didn’t really pan out that way. How the marketplace evolves is still uncertain.