Pipes & Wires
From the editor’s desk…
Welcome
to Pipes & Wires #182. We start this issue with some emerging ideas on who
can own batteries, and then examine two regulatory policy issues from New
Zealand. We then examine four gas, rail and electricity revenue decisions. We
then examine the possibility of introducing competing generators in South
Africa, and ensuring sufficient winter supply in Sweden. This issue then concludes
with a look at the Australian Government’s rejection of a major acquisition.
I’d
take this opportunity to wish you and yours a joyful and restful Christmas and
New Year. Pipes & Wires will return in February 2019.
What we’re seeing…
· Re-integration of lines and energy as
distributors invest in generation.
· What seems like regulatory push-back
against the large transmission lines required to interconnect wind-farms.
· Heightening concern around foreign
ownership of essential infrastructure.
· A possible emerging trend of regulators
squeezing fixed monthly charges which are increasingly seen as interfering with
renewable energy policy objectives.
· Increasingly mixed messages about
closing down coal-fired stations to reduce emissions on the one hand, and
keeping them open to improve grid security on the other hand.
· Inquiries and reviews that are prompted
by security of supply scares having their official terms of reference
subordinate security of supply to reducing CO2 emissions.
· Legacy thermal generation facing
steeper evening ramping rates as solar hollows out the daily demand profile.
· Some regulators warming to the idea of
allowing a “sand pit” for electric companies to play with emerging technology
ideas in, and allowing recovery of the reasonable costs of that playing.
· Regulators defining multiple classes of
services and payment categories for battery storage.
· Diversified electric companies reducing
their exposure to volatile energy revenues and increasing their exposure to
predictable lines revenue (the opposite of what was fashionable a few years
ago).
· Heightened appreciation of coal-firing capability
during gas supply interruptions.
· A shortage of skilled project managers
and electricity network designers.
· Gas
turbine stations being recognised as important for providing grid security.
· A mixed bag of revenue determinations …
some tougher than expected, some easier.
Recent client projects
Recent
client projects include…
· Identifying learnings from the RIIO –
ED1 reset on behalf of an Australian distributor.
· Developing a smart metering strategy.
· Advising on likely available electrical
contractors.
· Undertaking a customer survey to
identify customer preferences for off-peak EV recharging.
· Developing a strategy for complying
with the related party transaction provisions.
· Advising on the regulatory implications
of an aging timber transmission pole fleet.
· Compiling some introductory thoughts on
digital transformation and blockchain.
· Facilitating a series of client
workshops to better understand asset information criticality and in-service
failure risk.
· Assessing the strength of asset
management practices.
· Reviewing recent AER decisions to
understand the expectations around asset management practices and methods.
· Reviewing the AER’s recent treatment of
network transformation expenditure.
· Compiling overhead conductor and wooden
cross-arm fleet strategies.
· Identifying the issues around
customer-owned lines on private land.
· Developing a risk-based tree trimming
strategy.
· Developing an EV charging strategy.
· Analysing transmission charges as a
percentage of total electric bills.
· Compiling a strategy for improving the
resilience of a sub-transmission network.
· Developing a best-practice guideline
for smart metering.
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Regulating emerging technologies
US – who can legally own batteries ?
Introduction
Who can legally own batteries
seems to be the next war within the wider battle of regulating emerging
technologies. This article examines a recent dispute in the US state of Texas,
and then tries to translate that into the New Zealand context.
The Texas dispute
Following AEP Texas’ application to the Texas Public Utilities Commission to use battery storage as an alternative to traditional grid
investment, several generators recently submitted to the TPUC that transmission
and distribution (T&D) companies cannot legally own batteries whilst other
parties including battery suppliers argued that it is legal. The key issue is
that the Public
Utility Regulatory Act (PURA)
inter alia prohibits T&D
companies operating with the Electric Reliability Council of Texas (ERCOT) from owning generation, with the implication that
batteries are classified as “generation”. Arguments include…
· In favor - that the PURA doesn’t prohibit T&D owning storage
devices for increasing reliability (as distinct from selling energy or
wholesaling ancillary services).
· Against - that PURA didn’t really contemplate non-traditional
technologies, and the declining cost of batteries means that third parties can
easily own batteries.
A way forward seems to be to
allow T&D to own batteries, but not participate in the energy market.
The New Zealand context
New Zealand is facing similar issues
to those described above in Texas…
· Retailers have disputed whether distributors should be allowed to
own and operate batteries within the scope of electricity line services.
· The Commerce Commission’s recent Electricity
Distribution Information Disclosure Amendments Determination 2017 require distributors to disclose forecast network expenditure and
constraints on a map (in the context of related party transactions) which
certainly lends itself to the distributor itself or a third party proposing to
install batteries instead of traditional network investment.
Pipes & Wires will keep
watching how regulators are treating batteries, solar panels and EV chargers.
Revenue and pricing frameworks
NZ – setting the framework for DPP3
Introduction
Non-exempt
electricity distribution businesses (EDB’s) are currently subject to the second default price-quality
path (DPP2) which expires on 31st March 2020. This article
examines the Commerce Commission’s recently released issues
paper on the DPP3 that
will apply from 1st April 2020.
Regulatory framework
The regulatory framework is set
out in Part 4
of the Commerce Act 1986…
· Subpart
3 sets
out the requirements for the Input Methodologies.
· Subpart
6 sets
out inter alia the requirements for the DPP.
Key features of the DPP3 issues paper
Key features of the DPP3 issues
paper include…
· How the Commission intends to set DPP3 in the context of its
statutory requirements.
· Setting out the Commission’s priorities for EDB’s, and how those
priorities will be reflected in DPP3.
· Sets out the core components of DPP3.
· Discusses specific DPP3 issues and how they might need to
addressed.
Those specific issues include…
· Implementing the change in the form of control from a
weighted-average price cap to a revenue cap as a result of the Input
Methodologies review in 2016.
· Provision for accelerated depreciation of assets (also as a result
of the 2016 Input Methodologies review).
· The transition to and from customised price-quality paths (CPP’s).
· Refining the process for dealing with requests to reconsider or
amend a DPP.
· How reliability performance will be managed, including setting
standards, setting reliability incentives, and how SAIDI and SAIFI might be
normalised.
· Whether other dimensions of supply quality should be considered,
including fault response time, phone answering time, time taken to process a
new connection application, and providing sufficient notice of planned
shutdowns.
As always, interested parties
should read the detail of the papers for themselves.
Next steps
The next steps include
consultation on the issues paper until 20th December 2018, receiving
cross-submissions until 31st January 2019, workshops on specific
issues during February and March 2019, and the release of the Draft DPP
Decision during May 2019.
NZ – accelerated
depreciation for electricity lines
Introduction
Pipes
& Wires #178 noted the Commerce
Commission’s draft Electricity
Distribution Services Input Methodologies Amendments Determination 2018 and the associated draft
Reasons Paper in
regard to accelerated depreciation of electricity distribution assets. This
article examines the key features of the Electricity
Distribution Services Input Methodologies (Accelerated Depreciation) Amendments
Determination 2018.
Regulatory framework
The regulatory framework is set
out in Part 4
of the Commerce Act 1986…
· Subpart
3 sets
out the requirements for the Input Methodologies.
· Subpart
6 sets
out the requirements for the DPP.
Key features of the
Amendments Determination
Key
features of the Amendments Determination include…
· The
amendments apply for a DPP in force from 1st April 2020.
· The
definition of adjusted depreciation has been amended.
· The
introduction of limits to the adjustment factor.
As
always, interested readers should examine the detail of the Determination and
the Reasons Paper themselves.
Next steps
Interested
parties should note the 1st March 2019 as the final date for
submitting applications for accelerated depreciation.
Revenue and pricing decisions
NZ – gas under pressure
Introduction
The Commerce Commission recently released its
cost of capital
determination that will apply for the Disclosure Year
2019 for the gas pipeline businesses owned by First Gas (transmission and distribution) and Powerco (distribution only). This article examines
the key features of that determination.
Regulatory frameworks
The regulatory framework for setting the gas pipeline WACCs are set out
in…
· Clauses 4.4.1 to
4.4.10 of the Gas Distribution Services Input
Methodologies Determination 2012.
· Clauses 4.4.1 to
4.4.10 of the Gas Transmission
Services Input Methodologies Determination 2012.
These determinations are made pursuant to Part 4 of the Commerce
Act 1986.
Key features of the
WACC’s
Key features of the WACC’s include…
Parameter |
25th percentile |
Mid-point |
67th percentile |
75th percentile |
Vanilla WACC |
4.64% |
5.34% |
5.80% |
6.05% |
Post-tax WACC |
4.17% |
4.88% |
5.34% |
5.58% |
UK – the final rail price determination
Introduction
Pipes
& Wires #166, #173 and #177 examined the PR18
price review that
will apply to Network
Rail for
the CP6 control period from 1st April 2019 to 31st March
2024. This article recaps the process to date and examines the Office of Rail
Regulation’s final
determination.
Key features of the CP6 Strategic Business Plans
Key features of Network Rail’s CP6
Strategic Business Plans
include…
· Improved passenger and public safety, including reducing the risk
of train accidents by 10% and the risk of level crossing incidents by 13%.
· Reducing the number of delayed trains by 15%.
· Reducing operating costs per passenger kilometer by 9%.
Key features of the draft decision
Key features of the draft
decision include…
· A requirement for further engagement with the train operating
companies on performance trajectories.
· An expectation that costs will be reduced by about £1b.
· Whilst stakeholder engagement was good, it could be improved. In
particular some stakeholders felt that the engagement process was more like
communicating a pre-determined outcome.
· An expectation of more explicit trade-offs around competing
priorities.
· Concerns about the tracks’ ability to accept specific types of
freight rolling stock, including speed, availability and electrification.
The final determination
Key features of the final
determination
include…
· A broad acceptance that the proposed expenditure for each route was
appropriate.
· A general acceptance that asset sustainability could be achieved
with about £500m of RepEx, down from the £1b that ORR proposed in its draft
determination.
· An increase in efficiency gains from £460m to £617m.
· An acceptance that an additional £80m should be spent on safety.
· An acceptance of the £245m proposed for research and development.
· A nett revenue requirement of £37.4b.
This concludes Pipes &
Wires analysis of the UK rail pricing (at least for another 4 years).
Aus – the NSW electricity distribution Draft Determinations
Introduction
The Australian Energy Regulator recently released its Draft Determinations for the 3 electricity
distributors in NSW (Ausgrid, Endeavour
Energy and Essential Energy) for the 5 year period commencing on 1st July 2019.
This article examines the key features of those Draft Determinations.
Regulatory framework
The basis of the regulatory
framework is Chapter
6a of the National Electricity Rules, which are made pursuant to the National
Electricity Law.
Ausgrid - key features of the revenue reset process
Key features of the process to
date include…
Parameter |
Proposal |
Draft Determination |
Revised Proposal |
Final Determination |
CapEx |
$3,084m |
$2,209m |
|
|
OpEx |
$2,402m |
$2,344m |
|
|
Opening RAB |
$15,716m |
$15,683m |
|
|
WACC |
6.33% |
5.96% |
|
|
Depreciation |
$713m |
$726m |
|
|
Smoothed revenue |
$8,918m |
$7,940m |
|
|
Endeavour Energy - key features of the revenue reset process
Key features of the process to
date include…
Parameter |
Proposal |
Draft Determination |
Revised Proposal |
Final Determination |
CapEx |
$2,166m |
$1,700m |
|
|
OpEx |
$1,486m |
$1,468m |
|
|
Opening RAB |
$6,512m |
$6,512m |
|
|
WACC |
6.11% |
5.96% |
|
|
Depreciation |
$504m |
$631m |
|
|
Smoothed revenue |
$3,892m |
$4,413m |
|
|
Essential Energy - key features of the revenue reset process
Key features of the process to
date include…
Parameter |
Proposal |
Draft Determination |
Revised Proposal |
Final Determination |
CapEx |
$2,100m |
$2,081m |
|
|
OpEx |
$1,698m |
$1,718m |
|
|
Opening RAB |
$8,215m |
$8,215m |
|
|
WACC |
6.34% |
5.96% |
|
|
Depreciation |
$632m |
$716m |
|
|
Smoothed revenue |
$5,142m |
$5,292m |
|
|
Pipes & Wires will revisit
this story when the 3 distributors submit their Revised Proposals.
South Africa – setting Eskom’s fourth price determination
Introduction
Eskom recently submitted its application to the National Energy Regulator (NERSA) for the fourth Multi-Year Price Determination (MYPD4) for
the period 1st April 2019 to 31st March 2022*.
This article summarises the key features of the MYPD4 application to set some
context for examining NERSA’s decisions.
* NERSA’s revenue and tariff
decisions will apply from 1st April 2019 for Eskom’s non-municipal
customers, and from 1st July 2019 for municipal customers.
Regulatory framework
The over-arching regulatory
framework is the Electricity
Regulation Act 2006, which
inter alia provides for the recovery of efficient costs by the licensee and
approval of tariffs by NERSA.
Key feature of the MYPD4 proposal
Key features of the MYPD4
proposal
include…
Parameter |
Proposal |
Decision |
Expenditure |
R179b |
|
Primary energy |
R229b |
|
Opening RAB |
R1,268b |
|
Depreciation |
R213b |
|
Local IPP’s |
R105b |
|
Returns |
R0.86b |
|
Revenue |
R763b |
|
Pipes & Wires will comment
further once NERSA’s decision emerges (expected to be around March 2019).
Energy markets & restructuring
South Africa – introducing competing
generators
Introduction
News
emerged recently that the Democratic Alliance introduced a private members
bill that would introduce competition by inter alia breaking up Eskom into competing generation companies
(which is actually the latest of several attempts to introduce competition
stemming back to 2011). This article briefly examines the DA’s bill as a
starting point for considering the key features of breaking up a vertically
integrated electric company.
The DA’s bill
The
DA introduced the Independent System & Market Operator Bill in late
October. The key feature of the Bill is to establish an independent,
state-owned entity that will buy electricity from competing generators
including from independent power producers (IPP’s), however it appears that
financially strong municipalities may also be able to buy electricity directly
from generators through a transparent trading function.
Breaking up a vertically integrated
electric company
Breaking
up a vertically integrated electric company essentially involves 4 activities…
· Establishment of the transmission grid
as a separate entity that provides transparent access to all generators that
meet its technical and commercial standards.
· Breaking the generation fleet into
competing businesses. There may also be limits to the market share of the newly
established generators, effectively requiring any additional generation to be
built by an IPP.
· Establishment of a market and system
operator to dispatch generation based on bids, and then to transact the
purchased electricity. This entity may also be responsible for transmission
grid planning (eg. the AEMO in Australia).
· Establishment of an economic regulator
to inter alia set the prices (or
revenue) and reliability of the transmission and distribution activities. South
Africa has already established NERSA as its economic regulator.
Exploring the generation breakup in
more detail
A
little thought would reveal that breaking up a generation fleet into competing
businesses could prove difficult if the legacy plant has been built around a
merit order (eg. Western Australia), includes thermal and hydro with small
catchments (eg. New Zealand), or includes nuclear decommissioning liabilities
(eg. Britain). In contrast, Eskom’s generation fleet comprises…
· A broad mix of coal-fired steam turbine
plant of varying ages and thermal efficiencies, and perhaps more importantly,
differing coal supply arrangements and costs.
· The 1 nuclear plant at Koeburg.
· A fleet of pumped storage and gas
turbine peaking plants.
So
at least on the face of it forming several competing generators each with a mix
of similar baseload and peaking plant should be straightforward. Pipes &
Wires will re-visit this issue as the ISMO Bill progresses through the
parliamentary process.
Energy mix and grid security
Sweden – ensuring secure supply for winter
Introduction
Over the last decade, Sweden has exported
about 10% to 15% of its annual generation (between 10,000 GWh and 20,000 GWh).
These are, however, annual figures which don’t reflect the shifting patterns of
export and import during any 1 year, and it is the possibility of having to
import electricity during the 2018/19 winter that is the focus of this article.
Some wider context
Pipes & Wires #154 and #172
examined Sweden’s surprising swing back towards nuclear energy. Key features of
the swing back towards nuclear energy included…
· Phasing out of the tax on nuclear
electricity that was introduced in 1984 and is currently €7.5 per MWh (about
33% of the cost of nuclear generation). This tax generates annual revenues of
about €465m.
· Allowing the construction of up to 10
new nuclear reactors to replace aging reactors.
· A target of 100% renewable energy by
2040 (which is clearly underscored as a goal, and not as a final cut-off date
for the nuclear generation).
The
expected end-of-life closure of nuclear generation will create a capacity
shortfall of about 3,300 MW by 2040 (just under 10% of currently installed
capacity) and possibly 7,000 MW by 2045.
Sweden’s current supply situation
Sweden’s peak demand is about 27,000 MW,
whilst installed capacity is about 37,000 MW as follows…
· 9,300 MW – nuclear.
· 16,200 MW – hydro.
· 3,700 MW – wind.
· 8,000 MW - other thermal generation.
So on the face of it there is about 10,000
MW of reserve capacity margin (excluding imports), or about 35% which is
significantly more than the 15% to 18% that was traditionally planned for. That
is until we consider the following issues…
· The possibility of a “1 in 10 cold winter” which
drives demand even higher.
· The closure firstly of Oskarshamm #1 (500
MW) in June 2017 and then the planned closure of Ringhals #1 and #2 (1,730 MW) in 2019 and 2020 which will remove 2,230
MW of secure generation from the supply curve.
· The possibility of little or no wind (especially
during a really cold winter), which could remove a further 3,000 MW from the
supply curve.
Putting aside any low hydro storage or
inflows, the above 3 issues alone could remove over half of the reserve
capacity margin suggesting that additional secure generation will be needed.
Pipes & Wires will pick up this story again after the northern winter to
see how the reserve margin fared and what remedial actions have resulted.
Merger & acquisitions
Aus – federal government rejects CKI bid
Introduction
Pipes
& Wires #177, #179 and #181 examined CK
Infrastructure’s bid
for the APA
Group. This
article examines the Australian government’s rejection of that bid in November
2018.
Quick recap of the deal so far
CK Infrastructure’s launched
its’ A$13b bid for APA which would create an enlarged CK Infrastructure that would have
electricity distribution, gas distribution or gas transmission assets in all
jurisdictions except Tasmania. Key events include…
· In mid-August 2018, APA’s board recommended that shareholders
accept the $13b bid, which at that time was still subject to regulatory
approval.
· The ACCC approved the bid in mid-September 2018. This included a
court-enforceable undertaking from CKI that it would sell the APA pipelines in
Western Australia to maintain competition in the gas transmission pipeline
market because it (CKI) already owns a stake in the Dampier – Bunbury pipeline.
· In early November the government handed down a preliminary
rejection of CKI’s proposal which apparently left room for a revised offer
which many analysts said was unlikely.
The rejection
The government’s final decision was to
outrightly reject the proposal, stating that it would be contrary to the
national interest. Treasurer Josh Frydenburg elaborated "I have formed this view on the basis that
it would result in a single foreign company group having sole ownership and
control over Australia’s most significant gas transmission business".
This concludes Pipes &
wires coverage of this deal.
General stuff
Guide to NZ electricity laws
I’ve
compiled a “wall chart” setting out the relationship between various past and
present electricity Acts, Regulations, Codes etc in sort of a chronological
progression. To request your free copy, pick here. It looks really cool printed in color
as an A2 or A1 size.
A bit of light-hearted humor
What
if price control had been around in the 1920’s and 1930’s ? A collection of classic
historical photo’s with humorous captions looks at some of the salient features
of price control. Pick here to download.
A potted history of electricity
transmission
I’ve
recently compiled a potted history of electricity transmission. Pick here to download.
Video series – Powering NZ
The
team at Whiteboard Energy are compiling a series of cool 20 minutes videos on
the history of electricity in NZ, which are now on YouTube…
· Episode #1 – The Powerboard Of Fame.
· Episode #2 – The Power Of The State.
· Episode #3 – The People Want More.
The
series eventually will run to 5 episodes … an opportunity to fund Episode #5 is
here.
Wanted – old electricity history books
Now
that I seem to have scrounged pretty much every book on the history of
electricity in New Zealand, I’m keen to obtain historical book, journals and
pamphlets from other countries. A couple of titles are of particular interest
to me…
· Power System Economics – Designing
Markets for Electricity by Steven Stoft.
· Electrifying America – Social Meaning
of a New Technology by David E. Nye.
· The California Electricity Crisis by
James L. Sweeney.
· TVA’s Public Planning – The Vision, The
Reality by Walter L. Creese.
· Electricity Restructuring – The Texas
Story by Lynne Kiesling and Andrew N. Kleit.
So if anyone has a copy of these books they no
longer want, please email me.
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Disclaimer
These articles
are of a general nature and are not intended as specific legal, consulting or
investment advice, and are correct at the time of writing. In particular Pipes
& Wires may make forward looking or speculative statements, projections or
estimates of such matters as industry structural changes, merger outcomes or
regulatory determinations. These articles also summarise lengthy documents, and it is important that
readers refer to those documents in forming opinions or taking action.
Utility
Consultants Ltd accepts no liability for action or inaction based on the
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