Pipes & Wires
From the editor’s desk…
Welcome
to Pipes & Wires #194, which starts with a look at the third electricity
distribution price control in New Zealand. We then look at how the undersea
cables between France and Britain might be regulated in a post-Brexit world,
and examine the slowing progress with the Hinckley Point C nuclear power
station. Following that we look at some industry structural changes in the USA
and South Africa, and conclude with two tariff issues in the USA.
I’d
like to wish you and yours a merry Christmas, and Pipes & Wires will return
(probably) in February 2020.
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 third electricity distribution price-quality
path
Introduction
The Commerce Commission
recently released its final
default price-quality path that
will apply to all non-exempt EDB’s (that are not subject to a CPP) for the 5
year control period beginning on 1st April 2020 (DPP3). This article
compares the key features of the final decision with the draft decision.
Regulatory framework
Subpart
6 of Part 4 of the Commerce Act 1986 sets out the regulatory framework for default price-quality
regulation in general, whilst Subpart
9 sets
out specific provisions for EDB’s.
Key features of the final decision
Key features of the final
decision include…
Feature |
DPP2 |
DPP3 draft |
DPP3 final |
Average reduction in Year 1
revenue. |
|
A decrease of 4.6%, down to
$1.04b across the industry (ranging from a 9% increase for Aurora to a 34%
reduction for Centralines). |
A decrease of 6.7%, down to
$1.01b across the industry (ranging from a 3% increase for Aurora to a 29%
reduction for Centralines). |
Total revenue |
$5,146m |
$5,436m, an increase of 6%
from DPP2. |
$5,259m, an increase of 2.4%
from DPP2. |
WACC |
7.19%. |
5.13%. |
4.57%. |
Control instrument |
Price cap. |
Revenue cap. |
Revenue cap |
Treatment of interruptions |
Treat planned and unplanned
similarly. |
Treat planned and unplanned
separately. |
Treat planned and unplanned
separately. |
Recoverable innovation
allowance |
Nil. |
Proposed innovation
allowance, capped at 0.1% of revenue. |
$150,000 per EDB, capped at
0.1% of revenue for total DPP3 period. |
Re-openers |
Nil. |
Proposed re-opener for large
unforeseen connections (in preference to including allowances for uncertain
projects at the start). |
Specific CapEx projects,
including major industrial electrification or substantial growth. |
As always, interested parties
should read the full decision and accompanying papers. This concludes Pipes
& Wires coverage of DPP3.
Europe – regulating in a post-Brexit world
Introduction
Interconnection
of electricity transmission grids is something most people probably take for
granted, and perhaps more so the body of international law that underpins those
regulatory frameworks. This brief article notes various regulatory concerns
over what Brexit could mean for 3 proposed electric transmission
interconnectors between England and France.
The 3 proposed interconnectors
The 3
proposed interconnectors are…
· GridLink Interconnector, a
1,400MW HVDC link between Dunkerque and Kingsnorth.
· FAB, a
1,400MW link that includes several 400kV overhead lines and a 320kV HVDC cable
between Siouville-Hague and Budleigh Salterton (with 1km of land cables across
the island of Alderney).
· Aquind, a
2,000MW, 320kV HVDC link between Lovedean and Barnabos.
All
together that’s about 4,800MW of new interconnection capacity.
The regulatory concerns
Much
thought has already gone into the issues around importing and exporting
electricity should Britain leave the EU, with those imports and exports
currently being tariff-free as part of the EU’s Internal
Energy Market (IEM). The key
concern appears to be allocation of day-ahead transmission capacity, for which
the French energy regulator CRE has
already approved for the existing 2,000MW IFA. The
CRE’s specific concern is that such arrangements could lapse if Brexit proceeds
to completion.
NZ – setting the WACC for gas pipelines
Introduction
The Commerce Commission recently released its cost of capital
decisions for the year ending on 30th
September 2020 for First Gas and Powerco’s gas distribution businesses. This
article examines the key features of that determination.
Regulatory frameworks
The regulatory framework is set out in clauses 2.4.1 to 2.4.9 of the Gas Distribution
Services Input Methodologies Determination 2012 (consolidated to 3rd
April 2018).
Key features of WACC’s
Key features of the First Gas and Powerco WACC’s include…
|
25th percentile |
Mid-point |
67th percentile |
75th percentile |
Vanilla WACC |
3.70% |
4.40% |
4.87% |
5.11% |
Post-tax WACC |
3.36% |
4.07% |
4.53% |
4.78% |
Cool video clips
Building the Hoover dam
This time-lapse video of
the Hoover Dam being built is
worth a look at, which appears to cover the period from June 1933 to May 1935.
To give some perspective of the size of the dam, each 18 ton bucket of concrete
raised the height only 1 inch.
If you do happen to be in Las
Vegas, it’s well worth driving the 40 miles out to the dam. I’d suggest
obtaining tickets from the official Bureau Of
Reclamation website rather
than from a commercial tour operator.
Energy mix, emissions and grid security
UK – progress slows on Hinkley Point C
Introduction
Pipes & Wires has recently
examined the following nuclear power stations that have adopted the European
Pressured Water Reactor (EPR) technology…
· Hinkley Point C – England.
This article re-examines Hinkley
Point C on
news that construction has slowed.
Construction slows, costs rise
The builders of Hinkley Point C
(Electricité
de France and China
General Nuclear Power Corporation) have recently reported that “challenging ground conditions” will
increase the final construction costs by £2.9b (which the contract requires the
builders to absorb, not the owners), to somewhere between £21.5b and £22.5b. It
appears that the number of faulted zones through the mudstone and limestone is
more than the original soil testing revealed.
Commissioning of Unit #1 is
still planned for the end of 2025, however the probability of a 15 month delay
has risen.
Implications for investment
Pipes
& Wires #171 noted
that EDF’s expected ROI was 9%, and that every £1b cost over-run would dilute
that ROI by about 0.36%. This cursory analysis suggests that these challenging
ground conditions will dilute the ROI to a bit less than 8%.
Summarising progress
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 |
Hinkley
Point C |
Start
date |
2007 |
2005 |
2008 |
Early 2018 |
Original
completion date |
2012 |
2010 |
2012 |
Late 2025 |
Estimated
completion date |
2019 (7 year delay) |
2020 (10 year delay) |
2018 (6½ year delay) |
Early 2027 ? |
Original
cost estimate |
€3.3b |
€3.7b |
€8b |
£18b |
Likely
cost to completion |
€10.9b |
€8b |
Thought to be €15b |
£21.5b – £22.5b |
Pipes & Wires will continue examining Hinkley
Point C, Flammanville #3 and Olkiluoto #3 as they progress. Readers with an interest in UK infrastructure can subscribe to New Civil Engineer’s weekly news feed.
Industry structural changes
US – merger in the Sunshine State
Introduction
Against
a backdrop of several cities wanting to form muni’s (Boulder, Chicago, San
Francisco and San Jose to name just a few), the city of Jacksonville, Florida
is selling its municipal electric and water business. This article examines that sale
process.
A bit about the Jacksonville Electric Authority
JEA
is based in Jacksonville, Florida. It supplies 478,000 electric customers,
357,000 water customers and 279,000 sewage customers, and has annual revenues
of about $1.85b. JEA is the largest muni in
Florida and the 8th largest muni in the US.
The sale process
Back
in August 2019 JEA sought
competitive bids from investors aligned to its strategic goals, which are
now being evaluated using a structured weighting method. The bidding documents valued JEA at
about $5.4b, but indicated that bids would need to be in the range of $6.8b to
$7.3b to even get consideration (external valuations seem to range from $7.5b
to as much as $11b).
Selling
a muni does seem to be against the current trend, and it appears that most
Jacksonville residents and some city councilors oppose the sale process.
Known bidders
Known
bidders include NextEra Energy (Florida Power
& Light’s parent, which recently paid $5.75b for Gulf Power), Duke Energy, Macquarie and IFM Investors ... all very capable investors with
deep pockets who understand how to capture amalgamation synergies.
Next steps
Pipes
& Wires will comment further when a winner emerges.
South
Africa – proposed break up of Eskom
Introduction
Many readers will be aware that South
Africa’s state-owned, vertically integrated electric company Eskom has had
a difficult few years. This article notes the various reports over the last
year or so that Eskom will be broken up so we’ve got some context for examining
any changes that may emerge.
The
proposed break up
The proposed break up includes…
· The
formation of 3 separate operating companies (generation, transmission and
distribution) all owned by a holding company over a 3 to 5 year period.
· Spinning
off the transmission business into a separate state-owned company, possibly as
quickly as 18 months.
· Introducing
competition from independent power producers (IPP’s).
· Shareholder
support (ie. government bailouts) totaling R128b over the next 3 years.
· A
commitment that “key assets of the government” will not be privatised.
The
various views on the break up
Various views on the break up include…
· Not
surprisingly the various electricity and coal mining unions are dead against
any break up, despite assurances that it won’t continue through to
privatisation.
· The
Department of Public Enterprises seems hesitant with the details, including how
debt will be apportioned between the 3 businesses.
· Treasury
is of the view that some generation could be sold.
· Credit
rating agency Moody’s seemed unimpressed, further cutting Eskom’s credit rating
to below investment grade.
The editor comments
A few comments from me…
· Breaking
up Eskom won’t fix the financial losses, but it could help focus attention on
where (and perhaps why) the losses are occurring.
· Allocation
of debt will be critical … it could be cynically argued that the debt could be
allocated to the monopoly transmission and distribution businesses to avoid
encumbering the competitive generation business (presumably sequestering
Eskom’s debt into a separate state-owned company is not an option, as it was in
Ontario, Canada).
· Eskom’s
current generation fleet would seem to include some evenly-matched stations
that could be broken into evenly-matched competing businesses … allocate some
base-load coal along with some gas turbines, pumped storage and wind to form
say 3 or 4 competing generation businesses, possibly allocate Koeburg to a
slightly bigger thermal business to carry the eventual decommissioning costs
(as was originally planned for National Power in the UK), or keep Koeburg as a
separate state-owned company (similar to how the nuclear stations in the UK
ended up).
Next
steps
Pipes & Wires will comment further as
the proposed break up progresses.
Regulating emerging technologies
US – rebalancing
fixed charges to reduce solar subsidies
Introduction
Exactly how much non-solar customers are
subsidising customers with solar is an ongoing debate. This article briefly examines
an apparently big increase that San Diego Gas & Electric (SDG&E)
recently proposed.
The
proposed tariff increase
The proposed tariff increase will see an
increase in SDG&E’s minimum monthly charge from about $10 to about $38. The
underlying principle is a migration from variable (kWh) charges to a fixed
daily charge, principally to ensure fairer recovery of the high fixed costs (readers
should be very familiar with this argument).
The
various views
Various views include…
· The California Solar & Storage Association claims
that the existing tiered tariffs will save solar customers more than the move
to TOU metering associated with the tariff rebalancing (required by the California Public Utilities Commission).
· PV
Magazine is understandably dismissive of SDG&E’s approach, and claims that
the argument of cost shifting lacks factual evidence.
· The
California Public Utilities Commission acknowledges its requirement for
electric companies to adopt TOU metering, and notes that timing will be
critical to integrating renewables (suggesting a big role for batteries).
· Lawrence
Berkeley National Laboratories claim
that cost shifting could be negligible under
some specific combinations of value of solar and cost to supply (it would seem
that it is the value of solar that is heavily disputed).
Next
steps
The CPUC is expected to decide on the
proposal around March or April 2020.
Energy markets & tariffs
US –
decoupling revenue from consumption
Introduction
Most of us will be well aware that electric
companies have high fixed costs, and that Ramsey Pricing says inter alia the most efficient way to
recover high fixed costs is through fixed tariffs. This article examines the
movement towards increasing fixed costs and a corresponding reduction in
variable costs using a recent article about First Energy as a
starting point.
The
trend towards fixed tariffs
Traditional electric tariffs have included
both a fixed component and a variable (kWh) component, and as long as
customers’ kWh consumption patterns didn’t vary too far from the annual kWh
consumption underpinning the tariff calculation there was no decline in
revenue.
The first squeeze on kWh consumption came
from the move toward improved energy efficiency, which has been really
overtaken by the rooftop solar movement. Not surprisingly, electric companies
are wanting to bias their tariffs towards those fixed components, which gives
an electric company less incentive to discourage energy efficiency and rooftop
solar. Promoters of both energy efficiency and rooftop solar, in contrast,
argue that reducing the kWh component of the tariff undermines their value
proposition (which it certainly does).
Allowing
revenue decoupling
Increased kWh consumption tends to be 1 of
the few ways that an electric company can increase its revenue during a rate
period, which obviously discourages promotion of energy efficiency. Regulators
have devised a range
of regulatory mechanisms to compensate electric companies for reductions in kWh
consumption that include…
· Decoupling
revenue from consumption, so that recovery of the high fixed costs is more
certain.
· Lost-revenue
adjustment mechanisms, which allow recovery of lost revenue based on the
estimated decline in kWh throughput.
· Performance
incentives that allow additional revenue for achieving specific targets such as
energy efficiency programs.
Variations of these mechanisms have been
adopted in 44 states and Washington DC.
FirstEnergy’s
proposal
First Energy is in the process of filing
rate cases with the Ohio Public Utilities Commission (PUC) for its 3 electric
distribution businesses (Ohio Edison, The
Illuminating Company and Toledo
Edison). The key feature
of the rate cases is the decoupling of revenue from kWh consumption, providing
First Energy with greater revenue certainty.
Pipes & Wires will pick up this story
again around March 2020 when the Ohio PUC releases it decisions.
Recent client projects
Recent
client projects include…
· Identifying best practices in
grid-scale and community-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.
Utility
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