Tag Archives: zero net energy

A misguided perspective on California’s rooftop solar policy

Severin Borenstein at the Energy Institute at Haas has taken another shot at solar rooftop net energy metering (NEM). He has been a continual critic of California’s energy decentralization policies such as those on distribution energy resources (DER) and community choice aggregators (CCAs). And his viewpoints have been influential at the California Public Utilities Commission.

I read these two statements in his blog post and come to a very different conclusions:

“(I)ndividuals and businesses make investments in response to those policies, and many come to believe that they have a right to see those policies continue indefinitely.”

Yes, the investor owned utilities and certain large scale renewable firms have come to believe that they have a right to see their subsidies continue indefinitely. California utilities are receiving subsidies amounting to $5 billion a year due to poor generation portfolio management. You can see this in your bill with the PCIA. This dwarfs the purported subsidy from rooftop solar. Why no call for reforming how we recover these costs from ratepayers and force shareholder to carry their burden? (And I’m not even bringing up the other big source of rate increases in excessive transmission and distribution investment.)

Why wasn’t there a similar cry against bailing out PG&E in not one but TWO bankruptcies? Both PG&E and SCE have clearly relied on the belief that they deserve subsidies to continue staying in business. (SCE has ridden along behind PG&E in both cases to gain the spoils.) The focus needs to be on ALL players here if these types of subsidies are to be called out.

“(T)he reactions have largely been about how much subsidy rooftop solar companies in California need in order to stay in business.”

We are monitoring two very different sets of media then. I see much more about the ability of consumers to maintain an ability to gain a modicum of energy independence from large monopolies that compel that those consumers buy their service with no viable escape. I also see a reactions about how this will undermine directly our ability to reduce GHG emissions. This directly conflicts with the CEC’s Title 24 building standards that use rooftop solar to achieve net zero energy and electrification in new homes.

Along with the effort to kill CCAs, the apparent proposed solution is to concentrate all power procurement into the hands of three large utilities who haven’t demonstrated a particularly adroit ability at managing their portfolios. Why should we put all of our eggs into one (or three) baskets?

Borenstein continues to rely on an incorrect construct for cost savings created by rooftop solar that relies on short-run hourly wholesale market prices instead of the long-term costs of constructing new power plants, transmission rates derived from average embedded costs instead of full incremental costs and an assumption that distribution investment is not avoided by DER contrary to the methods used in the utilities’ own rate filings. He also appears to ignore the benefits of co-locating generation and storage locally–a set up that becomes much less financially viable if a customer adds storage but is still connected to the grid.

Yes, there are problems with the current compensation model for NEM customers, but we also need to recognize our commitments to customers who made investments believing they were doing the right thing. We need to acknowledge the savings that they created for all of us and the push they gave to lower technology costs. We need to recognize the full set of values that these customers provide and how the current electric market structure is too broken to properly compensate what we want customers to do next–to add more storage. Yet, the real first step is to start at the source of the problem–out of control utility costs that ratepayers are forced to bear entirely.

AB1139 would undermine California’s efforts on climate change

Assembly Bill 1139 is offered as a supposed solution to unaffordable electricity rates for Californians. Unfortunately, the bill would undermine the state’s efforts to reduce greenhouse gas emissions by crippling several key initiatives that rely on wider deployment of rooftop solar and other distributed energy resources.

  • It will make complying with the Title 24 building code requiring solar panel on new houses prohibitively expensive. The new code pushes new houses to net zero electricity usage. AB 1139 would create a conflict with existing state laws and regulations.
  • The state’s initiative to increase housing and improve affordability will be dealt a blow if new homeowners have to pay for panels that won’t save them money.
  • It will make transportation electrification and the Governor’s executive order aiming for 100% new EVs by 2035 much more expensive because it will make it much less economic to use EVs for grid charging and will reduce the amount of direct solar panel charging.
  • Rooftop solar was installed as a long-term resource based on a contractual commitment by the utilities to maintain pricing terms for at least the life of the panels. Undermining that investment will undermine the incentive for consumers to participate in any state-directed conservation program to reduce energy or water use.

If the State Legislature wants to reduce ratepayer costs by revising contractual agreements, the more direct solution is to direct renegotiation of RPS PPAs. For PG&E, these contracts represent more than $1 billion a year in excess costs, which dwarfs any of the actual, if any, subsidies to NEM customers. The fact is that solar rooftops displaced the very expensive renewables that the IOUs signed, and probably led to a cancellation of auctions around 2015 that would have just further encumbered us.

The bill would force net energy metered (NEM) customers to pay twice for their power, once for the solar panels and again for the poor portfolio management decisions by the utilities. The utilities claim that $3 billion is being transferred from customers without solar to NEM customers. In SDG&E’s service territory, the claim is that the subsidy costs other ratepayers $230 per year, which translates to $1,438 per year for each NEM customer. But based on an average usage of 500 kWh per month, that implies each NEM customer is receiving a subsidy of $0.24/kWh compared to an average rate of $0.27 per kWh. In simple terms, SDG&E is claiming that rooftop solar saves almost nothing in avoided energy purchases and system investment. This contrasts with the presumption that energy efficiency improvements save utilities in avoided energy purchases and system investments. The math only works if one agrees with the utilities’ premise that they are entitled to sell power to serve an entire customer’s demand–in other words, solar rooftops shouldn’t exist.

Finally, this initiative would squash a key motivator that has driven enthusiasm in the public for growing environmental awareness. The message from the state would be that we can only rely on corporate America to solve our climate problems and that we can no longer take individual responsibility. That may be the biggest threat to achieving our climate management goals.

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.

What are the missing questions in California’s distribution planning OIR?

The CPUC has opened a long awaited rulemaking to revisit (or maybe visit for the first time!) how utilities should plan their distribution investments to better integrate with distributed energy resources (DER). State law now requires the utilities to file distribution plans by next July. But the CPUC may want to consider some deeper questions while formulating its policies.

To date the utilities have pretty much been able to make such investments with little oversight. For one client, AECA, we submitted testimony pointing out that PG&E had consistently overforecasted demand and used that demand to justify new distribution investment that probably is unneeded. Based on a corrected forecast that recognizes that that PG&E’s (and the state’s) demand has turned downward since 2007, PG&E’s loads don’t return to 2007 levels until at least 2014. (We found a similar pattern in SCE’s 2012 GRC filings.)

 

AECA - PG&E 2014 GRC Testimony: Comparing Demand Forecasts

AECA – PG&E 2014 GRC Testimony: Comparing Demand Forecasts

Both PG&E and SCE justified new investment based on phantom load growth, but they would have been better served to show what investment might be required for the evolving electricity market. SCE has responded with the Living Pilot that tests out how to best integrate preferred resources.

The CPUC is relying on Paul De Martini’s More than Smart paper as a roadmap for the rulemaking. The CPUC has asked a number of questions to be addressed by September 4 with replies September 17. A workshop is to be held September 18.Beyond these questions, two more questions come to mind.

First, who will be allowed to play in the DER world? The OIR asks about non-IOU ownership of distribution lines, particularly related to microgrids, but it doesn’t consider the flip side–can utilities or affiliates participate in the DER market? Setting market rules in the face of rapid evolution and uncertainty, current participants will look to protect their current interests unless they are shown a clear opportunity to gain the benefits of a new market. The CPUC ignores the political economy of rulemaking at our risk.

The second is how is this proceeding to be integrated with the multitude of other proceedings at the CPUC that set various resource targets? The LTPP, energy efficiency, demand response and solar initiatives, along with others, all seem to run on parallel tracks with little in the way of interactive feedback. Megawatt targets seem to be set arbitrarily with little evaluation of comparative resource costs and effectiveness, and more importantly, how these resources might best integrate with each other. How are the utilities to adapt to the spread of DER if the CPUC hasn’t considered how much DER might be installed?

Both of these questions are about market functionality. Who are the likely participants? What are their incentives to act in different situations? How would the CPUC prefer that then act? How are price signals to be coordinated to create the preferred incentives? The system investment and operation rules are a necessary component of anticipating the market evolution, but they are not sufficient. California ignored the incentives of market participants in the previous restructuring experiment, at the cost of $20 to $40 billion. We should take heed of what we’ve learned from the past about the paradigm we should use to approach this impending change.

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?

What we might expect for diffusion of new decentralized energy technologies?

Technologies and policies that enhance the development of decentralized energy resources have generated increasing interest over the last couple of years.  I’ll write more in the future about what are the underlying drivers, both technological and institutional.

I’ve been interested in the question of where do we stand, and how long might it take for diffusion of these new technologies. We can look back and see how technology transformed lives in just a couple of decades. Compare kitchens from 1900 and 1930; if we walked into the earlier kitchen, most of us would be lost, but we could whip up a meal in 1930.

 1030's Kitchen; Photo Credit - Henry Ford Museum

Or the rapid adoption of autos. In 1909, people could stand in the middle of Pike Street in Seattle and talk:

File:Seattle - Pike Street 1909.jpg

Not so safely in 1930:

Do we stand today at a point just at the onset of a new technological evolution?

One question to be answered is whether our institutional settings will allow these new technologies. In one case, it appears that Germany has already chosen its road. But in the US, whether we rely on central power stations using transmission lines may still be a question in play. That deserves a separate post of its own.

If we assume that we choose the decentralized path, what might we expect in when these technologies are adopted widely. A couple of graphics illustrate historic diffusion rates. This is one from VisualEconomics via The Atlantic:

Another one from Forbes via The Technium shows the parallel development paths (however, I don’t like starting at the year of invention instead of a threshold adoption level):

One might interpret the upper graph as showing accelerating adoption rates. But I interpret the lower chart as illustrating at least two factors that drive diffusion: the relative importance of network infrastructure and the expense relative to individual wealth.  Autos, telephones and electricity all required construction of a large network of roads or wires, often funded with public investment. Individuals can’t choose to adopt the technology until a larger public decision is made to facilitate that adoption.  As to expense, refrigerators and dishwashers were large household investments for many years, and cars are still a large single expenditure. On the other hand, cell phones, radios and televisions quickly became inexpensive which lubricated diffusion. We need another graphic showing how diffusion rates relate to these two different axes.

We are still unsure where decentralized energy technologies will fall among these characteristics. They may seem small and inexpensive, but enough solar panels to power a house will still be several thousand dollars for the foreseeable future. And the how much electric network investment is required to integrate these resources is the center of the debate over technology policies.

Too often studies making forecasts and policy recommendations don’t consider what adoption rates are feasible or probable. However a study comes along and incorporates this concept as its centerpiece. A good example is the Clean Energy Vision Project’s Western Grid 2050 report. Lead by a former colleague Carl Linvill, who’s now at the Regulatory Assistance Project, it looked at several different scenarios for technology diffusion. Such studies give us a better understanding of what’s actually possible rather than what we wish for.

Making Community Solar Gardens Work

California has been quite successful at encouraging the development of (1) large utility-scale renewables through the renewables portfolio standard (RPS) and other measures and (2) small-scale, single structure solar generation through the California Solar Initiative (CSI) and measures such as net energy metering (NEM).  However, there have been numerous market and regulatory barriers to developing and deploying the “in-between” community-scale and neighborhood-scale renewables that hold substantial promise.

Community-scale and neighborhood-scale distributed generation (DG) includes some technologies that simply are not cost-effective at the small scale of a single house or business, but are not large enough to justify the transaction costs of participating in the larger wholesale electricity market.  These resources, such as “community solar gardens”, can meet the demands of many customers who cannot take advantage of adding renewables at their location and can also reduce investment in expensive new transmission projects. Examples of these types of projects are parking structure-scale solar photovoltaics, solar-thermal generation and space cooling, and biogas and biomass projects, some of which could provide district heating.  Technology costs are falling so rapidly that these mid-scale projects are becoming competitive with utility-scale resources when transmission cost savings are factored in. SB 43 (Wolk 2013) recognizes that the promise of mid-scale renewables has not been realized.

In response to SB 43, each of the large investor-owned utilities–PG&E, SCE and SDG&E–have filed proposed tariffs with names such as Enhanced Community Renewables Program or Share the Sun. I filed testimony in the PG&E and SCE cases on behalf of the Sierra Club addressing shortcomings in those programs that would inhibit development of community solar gardens. SDG&E’s proposal, while not perfect, better meets the law’s objectives. After the hearings, the CPUC postponed a proposed decision from the July 1 deadline to October.

SB 43’s requirement that the investor-owned utilities “provide support for enhanced community renewables programs” is a critical step forward for California’s distributed energy goals.  The CSI is the state’s premier distributed generation program.  In SB 43 the Legislature expressed its intent that the “green tariff shared renewables program seeks to build on the success of the California Solar Initiative by expanding access to all eligible renewable energy resources to all ratepayers who are currently unable to access the benefits of onsite generation.”  SB 43 advances the success of the CSI into the area of multifamily residential and multitenant commercial properties and introduces all types of renewable energy resources.  Customers who, for various reasons, cannot benefit from the current net metering programs, will be able to benefit through SB 43.

The Legislature clearly intends for this program to lead to a transformation in the energy market akin to the success for single customers of the CSI. This necessary market transformation extends to multifamily and commercial lease properties that are currently beyond the CSI and Self Generation Incentive Programs (SGIP). The Commission should ensure that utilities’ programs under SB 43 provides the market transformation that is necessary for this underserved segment.

State regulations calls for all new residential dwellings to consume zero-net energy (ZNE) by 2020, and all new commercial properties by 2030.  Fully implementing the market transformation identified in SB 43 is one of the obvious means to achieve this target.  The CSI option has already facilitated many examples of feasible ZNE single-family homes using renewables well ahead of the 2020 deadline.  There are several market barriers to integrating renewables in a similar manner on multifamily and commercial leased properties and on single-family that are not favorably located or that have other impediments.

A properly-designed community solar garden program should provide a critical work-around for the split-incentive problem that has plagued local renewable development in California.  The split-incentive problem arises from the fact that multi-tenant structures, both commercial and residential, may not be able to implement solar or other renewable resources due to the fact that lessees are not the owners of the shared space where renewables could be sited.  The problem of split-incentives between landlords and tenants has long been recognized, and has been the focus of energy efficiency programs.

As a corollary, the Commission should provide individual developers and property owners the opportunity to integrate energy efficiency and DG measures to achieve the best mix for meeting environmental and economic goals. Each project is unique so that a “one size fits all” approach that requires sale of all output into the wholesale market with buyback from customers who may have no connection with the project will only discourage enhanced development.

For distributed generation to expand in California there must be a cost-effective path for residential and commercial tenants, as well as not-well-situated buildings, to install solar and other renewables and share the costs among other customers. The focus to date has been on either utility-scale or single-building scale projects, but the most promise may be in mid-scale projects that can serve a community or a neighborhood cost-effectively through a combination of scale economies and avoided transmission and distribution investment.  But to achieve this objective requires changes from current utility practices.

An update: Here’s the link to the decision on this CPUC case issued in January. And here’s the link to scoping memo for the phase of this proceeding.