Pipes & Wires
From the editor’s desk…
Welcome
to Pipes & Wires #193, which has been delayed 1 week to include analysis of
the Transpower revenue decision as the lead article. We then look at a gas
pipeline regulatory decision from Australia, and then it’s back to New Zealand
to examine the final report from the Electricity Price Review.
We
then examine a range of energy mix and grid security issues, including Australia’s
mounting concern about closing coal-fired stations (which will hopefully be
followed an article in December about the Liddell Task Force’s conclusions).
This
issue concludes with a look at efforts to buy PG&E’s distribution networks
around the San Francisco bay area, and a regulatory decision approving lower
feed-in tariffs. So … until next month, happy reading…
What we’re seeing…
Energy mix & grid security · Many events revealing that high
penetration of renewables is undermining grid security. · Increasing interest in nuclear to
provide both reliable and low emission generation. · Legal moves challenging the treatment
of forest bio-mass as renewable. · Heightened anxiety to get the carbon
price more precisely determined to unleash the next wave of decarbonisation
investment. · Diverging and seemingly inconsistent
views on the role of coal for dry-year security (less frequent, but more
critical). · Emerging battle between storing
solar, or over-building and curtailing · Charging EV’s with solar during the
day, and then use them to flatten the peaks. · 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. · Heightened appreciation of coal-firing
capability during gas supply interruptions. |
Regulating emerging technologies · Increasing numbers of US state
regulators removing EV chargers from the definition of public utility. · Policy makers exhibiting specific
technologies biases, particularly between batteries and gas turbines. · A possibly diminished role for gas
turbines as grid peaks are de-layered to allow more insightful use of
batteries. · Regulators defining multiple classes
of services and payment categories for battery storage. |
Network access and price regulation · Increasing regulatory rejection of
grid modernization, EV charger and smart meter proposals. · What seems like regulatory push-back
against the large transmission lines required to interconnect wind-farms. · A possible step change in direction
from the previous trend of regulators squeezing fixed monthly charges to
legislation specifically allowing solar tariffs. · 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. · A mixed bag of revenue determinations
… some tougher than expected, some easier. |
General stuff · A potential decoupling of electricity
prices from gas prices. · A possible need for a managed market
to strengthen certainty of gas supply. · The possibility of gas becoming
industry’s transition fuel away from coal. · More investment signals moving faster
and in different directions. · Increasing political awareness of the
need for a smooth transition that will minimise price shocks. · Mounting concern over the structural
integrity of many hydro dams, including the ability to fully de-water. · Heightening concern around foreign
ownership of essential infrastructure. · 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). · A shortage of skilled project
managers and electricity network designers. |
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Network regulatory decisions
NZ – finalising the next Transpower price-quality path
Introduction
The Commerce Commission
recently published its Final
Decision for the RCP3 control period that will apply to Transpower for the 5 year period commencing on
1st April 2020. This article examines the key features of that Decision.
Regulatory framework
The regulatory framework for
Transpower’s IPP is set out in Subpart
7 of Part 4 of the Commerce Act 1986.
Key features of the RCP3 decisions
Key features of the RCP3
decisions to date include…
Parameter |
RCP2 |
RCP3 draft proposal |
RCP3 final proposal |
RCP3 draft decision |
RCP3 final decision |
Revenue |
$4,731m |
$4,666m |
$4,419m |
$4,267m |
$4,045m |
OpEx |
$1,300m |
$1,333m |
$1,343m |
$1,304m |
$1,428m |
This concludes Pipes &
Wires coverage of the Transpower price-quality decision.
Aus – gas under pressure
Introduction
The
National Gas Rules require gas pipeline operators to submit a Reference Service Proposal (RSP) to the Australian Energy
Regulator (AER) at the start of the revenue reset process. This article
examines the Amadeus Gas Pipeline’s RSP submitted as part of the APT Pipelines
(NT) revenue reset for the 5 year period starting on 1st July 2021
to set some context for future analysis.
A bit about the Amadeus Gas Pipeline
The
Amadeus Gas Pipeline runs 1,630km from the Amadeus Basin in central Australia
to Darwin, with several laterals and 4 compressor station. The diameter varies
from 355mm down to 275mm.
Regulatory framework
The
regulatory framework includes…
· The National Gas (South Australia) Act 2008.
· The National Gas (Northern Territory) Act 2008.
· The National Gas Rules v49, of which Part 8 deals with Access
Arrangements (revenue reset).
Key features of the Reference Service Proposal
Essentially
the RSP sets out what services the pipeline operator will provide. The Amadeus
pipeline’s reference services include…
· Interconnection service – providing a
new receipt point.
· Firm transportation services –
commitment to capacity.
· Interruptible transportation service –
provides additional capacity when firm capacity is not available.
· In-pipe trade service – provides users
with flexibility for their transportation services.
· Operational capacity transfer service –
provides users with flexibility for their transport services.
· Parking and loan services – provide
users with flexibility for their transportation services.
Pipes
& Wires will comment further as the revenue reset process continues.
Energy markets & tariffs
NZ – concluding the Electricity Price
Review
Introduction
The Electricity Pricing Review team submitted its final report to the
Minister in late May 2019. This article follows on from previous introductory
articles by examining the Review’s Final Report.
Background to the Review
The
primary objective is to ensure that the electricity market delivers efficient,
fair and equitable prices as technology evolves and we transition to a lower
emissions future, taking into consideration environmental sustainability and
security of supply. So … a simple matter of figuring out where we are on the
energy trilemma, where we want (or can afford to be) to be, and how do we get
there.
The Review’s conclusions
The
following table compares the Review’s First Report with its Final Report…
Issue |
First
Report |
Final
Report |
Reliability |
The electricity system is
broadly reliable. Investment is sufficient to meet demand, at least for now. |
The
Security & Reliability Council should investigate the potential impact of
technology advances and other changes on long-term security and resilience. |
Emissions |
About 80% of demand is
already being met by renewable generation. This will help move towards zero
emissions. |
Confirmed
that NZ is well placed to reduce emissions, but great energy efficiency will
be essential to migrate to a low-carbon economy. This will require clearer,
coordinate government planning. More innovation from the energy sector is
required. |
Affordability |
Overall, the picture is not
so good. Since 2000, residential prices have risen faster than most other
OECD nations, and about 103,000 households spend more than 10% of their
household income on energy. |
Consumers
who don’t shop around are paying more than they need to. |
Fair pricing |
Again, not so good.
Residential prices have risen 79% since 1990, whilst industrial prices have
risen 18% and commercial prices have fallen 24%. |
No
further comments. |
Retail market |
This seems to be diverging
into 2 quite separate segments of those who enjoy low prices from shopping around
and capturing the prompt payment discounts, and those who don’t. |
The
Big Five have over 90% market share, so that independent retailers face
barriers to growing their market share. New energy products has increased
competition and led to lower prices for those who shop around, but reiterated
that two tiers are definitely developing. |
Subsidising emerging
technologies |
Current pricing structures
will result in subsidies from those who don’t have rooftop solar or EV’s to
those who do (long-time Pipes & Wires readers will recognise that such
subsidies are not new, and have long been a feature of air conditioners).
Moreover, the cost of any additional capacity for peak-time charging of EV’s
is likely to fall disproportionately on low-income customers. |
Reiterates
previous comments that distribution pricing is likely to be a barrier to
uptake of emerging technologies. |
Generation market power |
Some concerns have been
expressed about generators ability to exercise market power when supply is
tight. |
Wholesale
prices appear reasonable compared to the cost of building new generation, but
the contract market isn’t working well (limited ability of independent
generators and retailers to manage price risk). |
Decarbonisation |
This will obviously require a
lot more annual generation (almost double by my reckoning, requiring the
annual capacity factor to increase from about 50% to about 85%), but that
current market and industry arrangements should be able to meet demand growth
provided there are strong incentives to invest. |
Confirmed
that NZ is well placed to reduce emissions, but great energy efficiency will
be essential to migrate to a low-carbon economy. This will require clearer,
coordinate government planning. More innovation from the energy sector is
required. |
Transmission |
Decarbonisation will require
significant grid investment. These was no evidence that Transpower is making
excessive profits. |
Emphasised
that delays in agreeing on a fair, efficient and lasting transmission pricing
methodology risks undermining confidence and investment, and hence
recommended a government policy statement. Reiterated that profits are not
excessive. |
Distribution |
Several factors are thought
to be holding things back, including outdated pricing structures, aging
assets, the quality of governance, short planning horizons, access to meter
data, and the small size of distributors. There was no evidence that
distributors are making excessive profits. |
Confirmed
the factors identified in the first report, and recommended issuing a government
policy statement on distribution pricing. Ensure that smart meter data is
available to distributors on reasonable terms. Give the ComCom greater powers
to regulate distributors. Confirmed
that distributors are not making excessive profits. |
Retailers |
Competition has generally
increased, but not all customers have been able to take advantage of that. |
Phase
out the low fixed charge regulations, as the regulations are pushing some
families into greater hardship. |
The
Government proposed to adopt most of the Final Report’s 32 recommendations. This concludes Pipes & Wires
coverage of the Electricity Price Review.
Cool video clips
Steam turbines made simple (1946)
This
8 minute video clip explains how a steam turbine works,
especially how the fixed blades re-direct the steam on to each subsequent set
of rotating blades. I could’ve really used this video back in 1991 when I
started at Huntly.
Energy mix, emissions and grid security
Aus –
increasing concern over coal-fired closures
Introduction
There seems to be increasing concern around
the closure of coal-fired generation, particularly in the number, frequency and
increasingly official nature of those concerns. This article continues Pipes
& Wires’ on-going theme of the proposed closing of Australia’s coal-fired
generation using a recent speech by the AEMO as a starting point.
The key
concern of the recent AEMO speech
The key concern expressed by the AEMO is
not so much extending their lives beyond their original design lives, but rather
ensuring that they continue to operate for the remainder of their design lives
in the face of declining wholesale prices.
Key technical features of this specific
issue include…
· Increasing
penetration of wind generation is forcing down wholesale prices for individual
half-hours, often to near zero or even negative.
· Steam-turbine
generators have a lot of delicate components that operate at very high
temperatures (about 600oC).
· Repeated
cycling of those high temperatures can cause cracking, which increases
maintenance costs, consumes design life, and increases the risk of catastrophic
failure.
· Steam
turbine operators face the difficult choice of either incurring those costs to
remain in the market (and get paid), or exit the market. Either way grid
security is reduced.
Wider
context
The wider context to this issue includes…
· The
closure of Hazelwood back in 2017 and the consequent wholesale price rises
pushed this issue firmly on to the center stage (Pipes
& Wires #175), noting that
Hazelwood was actually the tenth coal-fired station to exit the NEM since 2012,
and the largest to exit since 1998.
· Then the
planned closure of Liddell in 2022 emerged, which is of course now the subject
of a joint Federal and NSW Government task force (Pipes
& Wires #192) that is expected
to report back later in 2019.
· Most
recently, the future of Yallourn W seems doubtful either from low wholesale
prices in the NEM or from the Victorian Government’s recently announced CO2
reduction targets.
Possible
remedies
Possible remedies to the specific issue of
early closures due to low wholesale prices include introducing a specific
market mechanism to pay coal stations to remain available, through to a wider
market overhaul. The AEMO’s preference appears to be to introduce an additional
market mechanism similar to the coal-fired reserve that was introduced in
Germany in 2015.
Pipes & wires will comment further once
the Liddell task force reports back.
Global –
WEC trilemma rankings
Introduction
The
World Energy Council recently released its 2019 Energy Trilemma Index. This article examines the underlying
principle of the Trilemma and notes the top performers.
The trilemma rating
The
trilemma is basically a triangle model that depicts how well a country is
balancing the trade-offs between the three important dimensions of…
· Security of energy supply.
· Accessibility and affordability of
energy.
· Environmental sustainability, including
both supply and demand side efficiencies and uptake of renewables.
Key features of the Index report
The
WEC’s website has a cool interactive graphic which is worth having a muck about
with to see which countries are ranked best in each of the indices. Picking the
country names jumps to a screen detailing that
country’s energy supply arrangements and also (perhaps equally important) that
country’s political, societal and economic performance. Not surprisingly the
top performers have a long history of stable and consistent energy policy that
has encouraged investment in security of supply, and perhaps also has
historically priced energy at a sustainable level that doesn’t require steep
price increases to recover the full cost of energy and energy supply.
The top performers
The
top performers for 2019 are…
Index
rank |
Country |
Score |
Rank
- security |
Rank
- equity |
Rank
- sustainability |
1. |
85.8 |
11th |
11th |
1st |
|
2. |
85.2 |
1st |
40th |
3rd |
|
3. |
84.7 |
2nd |
28th |
2nd |
|
4. |
81.5 |
28th |
19th |
6th |
|
5. |
81.1 |
3rd |
33rd |
28th |
What are the top performers of each
dimension doing ??
Let’s
consider what the Trilemma report has to say about the top performer in each
dimension…
Dimension |
Country |
Score |
What
that country is doing well |
Security |
Sweden |
79% |
· Reduced dependency on imported
energy. · Diverse energy supplies. · Stable transmission grid. |
Equity |
Luxembourg |
100% |
· Strong grid interconnections to
manage energy prices. |
Sustainability |
Switzerland |
89% |
· Optimising emissions across all
energy sub-sectors. |
A bit closer to home
The
rankings a bit closer to home are…
Country |
Index
rank |
Score |
Rank
- security |
Rank
- equity |
Rank
- sustainability |
10th |
79.4 |
20th |
26th |
29th |
|
28th |
74.7 |
43rd |
24th |
57th |
China – continuing the EPR story
Introduction
This article continues Pipes & Wires coverage of
the European Pressurised Water Reactors (EPR), this time at Taishan #1 and #2 in China. Taishan #1 was connected to
the grid in August 2018, whilst Taishan #2 achieved criticality in May 2019.
A bit about Taishan
Taishan is in the Guangdong Province, and comprises
two 1,750 MW reactors supplied by Areva. These are part of 11 reactors
totalling 10,800 MW under construction in China, and will add to China’s fleet
of 46 operational reactors totalling 42,800 MW.
Construction delays
Construction began in August 2008, and it was hoped
that each unit would take about 3 years and 10 months to build. These expected
build times were much less than Flammanville # and Olkiluoto #3, but were not
achieved. At least part of the delays were due to cracking and deficient
welding, which seems similar to Flammanville #3 and Olkiluoto #3.
Comparisons of costs and timing
A
quick comparison of Taishan #1 and #2 with Olkiluoto #3 and Flammanville #3
reveals the following…
|
Flammanville
#3 |
Olkiluoto
#3 |
Taishan
#1 and #2 |
Start
date |
2007 |
2005 |
2008 |
Original
completion date |
2012 |
2010 |
2012 |
Revised
completion date |
2019 (7 year delay) |
2020 (10 year delay) |
2018 (6½ year delay) |
Original
cost estimate |
€3.3b |
€3.7b |
€8b |
Likely
cost to completion |
€10.9b |
€8b |
Thought to be €15b |
Pipes & Wires will continue examining Hinkley
Point C, Flammanville #3 and Olkiluoto #3 as they progress.
Industry structural changes
US – San Francisco and San Jose offer
to buy PG&E’s network
Introduction
The
Cities of San Francisco and San Jose recently offered to buy the Pacific Gas
& Electric (PG&E) assets that supply parts of the respective cities.
This article examines the details of those proposals, and then considers some
wider observations in conjunction with other recent Pipes & Wires articles.
Electricity supply within San Francisco
The
San Francisco Public Utilities Commission* activities include
supplying electric power from the Hetch Hetchy
Power Scheme to the City & County of San Francisco and three of the
wider Bay Area counties. Hetch Hetchy and other renewable energy programs supply
about 80% of the City’s electricity. The precise commercial arrangement dates
back to 1918 and is legally complex involving firstly sale and purchase
agreements (up to about 1945) and then interconnection agreements (up to about
2015), but suffice to say energy is distributed to some parts of the City by
PG&E.
*
The SFPUC is a service delivery body, and is not to be confused with the state
regulator, the California Public Utilities Commission.
San Francisco’s proposal
The
headline story is that San Francisco has offered PG&E $2.5b for the
PG&E distribution assets within the City. A recent report from the SFPUC identified 3 options…
· Limited independence, in which the City
will simply continue to press for what it claims is fairer treatment from
PG&E. The SFPUC believes this option will represent a substantial barrier
to its renewable energy goals.
· Targeted independence, in which the
City will reinvest in the network it owns. The SFPUC claims that this option
would still leave many Hetch Hetchy customers dependent on PG&E, as well as
representing a barrier to its renewable energy goals
· Full independence, in which the City
will purchase PG&E’s network assets (thereby removing any interposing). The
SFPUC believes that this will reduce the barriers to its renewable energy
programs.
The
report recommends the full independence option by purchasing PG&E’s assets,
which it acknowledges to be a lengthy process. PG&E and City officials met
to discuss the City’s proposal in late September 2019, which PG&E subsequently declined in October 2019.
San Jose’s proposal
A
similar proposal to PG&E from San Jose hoped to persuade other cities and
counties to all agree to buy the respective assets of PG&E, effectively turning
PG&E into a cooperative (or perhaps a muni). This offer was declined by
PG&E in mid-October 2019.
Wider observations of proposed municipalisations
Pipes
& Wires has examined proposed municipalisations in the cities of Boulder,
Chicago and San Francisco, and has made the following observations…
· The historical context leading to each
of the 3 proposed municipalisations have a mix of common themes and quite
different themes.
· Each of the 3 municipalities believes
that it can offer its citizens a “fairer” deal, presumably lower prices. San
Francisco in particular has made some bold claims about giving priority to
safety, efficiency and more affordable prices.
· Each of the 3 municipalities also
believes that owning the network will assist renewable energy goals. Given that
embedded renewables are inextricably linked to the distribution network and
hence require the cooperation of the distribution business, they may well be
right. An obvious consequence is that fixed charges could be kept low as a matter
of public policy, but as we have observed that will probably lead to subsidies
and declining revenues.
· It is not clear that any of the 3
cities have considered possible loss of scale from separating from huge
electric companies (Xcel, Exelon and PG&E respectively). In fact,
PG&E’s reply suggests that San Francisco has significantly underestimated
the costs of separation.
Pipes & Wires will
comment as further news emerges.
Regulating emerging technologies
US –
paying less for injected rooftop solar electricity
Introduction
Arguments over how much rooftop solar
owners get paid for injected energy will be a familiar topic for most readers.
This article examines a recent regulatory
decision in the US state of
Louisiana approving lower prices for injected solar electricity to better
understand the analytical basis.
Recapping
the arguments
This specific issue is 1 strand of the
wider argument around prices charged to electric customers who also have their
own rooftop solar panels. The perspectives on the argument include…
· Electric
companies argue that an injected kWh is not the same as an imported kWh, and
doesn’t have the same value. There are a range of technical and commercial
arguments around avoided costs that include the additional costs of
bi-directional energy and subsidies from non-solar customers.
· Solar
owners, installers and lobbyists claim that offering lower prices for injected
kWh undermines the value of rooftop solar (which it certainly does), and
continue to promote the view that there is no subsidy.
The Louisiana
PSC’s decision
The wider context to this decision is the
LPSC’s nett metering rules that inter
alia required injected solar electricity to be priced at the electric
company’s full retail price for all injected kWh up to 0.5% of each company’s
monthly retail load, and at the avoided cost thereafter. Key features of the PSC’s
decision include…
· The 0.5%
cap will be removed.
· Solar installed
prior to 31st December 2019 will receive the full retail price until
31st December 2034 (ie. a 15 year grandfathering), and the avoided
cost thereafter.
· Solar
installed after 31st December 2019 will receive the avoided cost.
· The
avoided cost is the 12 month average locational marginal price for each
electric company, and shall be publically disclosed.
Wider public comments from the PSC include…
· The view
that Louisiana’s 2,000,000 electric customers should not be subsidising the
18,500 rooftop solar customers
· The view
that rooftop solar shouldn’t subsidies after years of nett metering.
· The view
that subsidies, if any, should be directed towards grid-scale solar which (the
LPSC claims) deliver about twice the value as rooftop.
Key
features of the Rule
Key features of the rule include…
· Payment
for injected energy shall be at prices that are cost-based.
· Those
costs shall not be subsidised by nor socialised across other customer classes.
Those 2 features alone suggest a sound
analytical basis.
Recent client projects
Recent
client projects include…
· Identifying best practices for
community-scale and grid-scale batteries for an Australian distributor.
· Identifying best practices in EV
charging on behalf of an Australian distributor.
· Recommending amendments to a security
of supply standard to better reflect demand density.
· Identifying best customer engagement
practices on behalf of an Australian distributor.
· Development of an asset management
journey aligned to ISO 55001.
· 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.
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.
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. So if anyone has any unwanted documents, 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.
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