Pipes & Wires

Though leadership of critical energy & infrastructure matters

Issue 197 – April 2020

 

From the editor’s desk…

 

Welcome to Pipes & Wires #197 ... not much has happened in New Zealand, so I would encourage readers to think through the trends and patterns in other jurisdictions, which include…

 

·     Challenges to Lithium-Ion both as the dominant battery chemistry, and as a storage technique.

 

·     Regulatory expectations that smart metering rate cases (proposals) will clearly demonstrate how customer benefits will be captured and shared.

 

·     Tightening gas supply, driven in part by the expectation that gas-fired electricity generation will increase to integrate variable renewables.

 

·     Tension between central and state-based investment planning.

 

So … until next month, happy reading…

 

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Technologies and techniques

 

Global – declining battery prices and emerging chemistries (part 2)

 

Introduction

 

Most of us are well aware that batteries are rapidly shifting on 2 dimensions … prices ($/kWh) are declining, and chemistries are also rapidly changing with a key dimension being increasing energy density (kWh/kg). This is part 2 of the 2 part article which started in Pipes & Wires #196, and which noted recent prices declines and presented some views on where prices and chemistries might go.

 

Changing applications for batteries

 

It appears that the cycle life, charging speed and energy density are somewhat mutually exclusive amongst the variant forms of Lithium-ion batteries, viz…

 

Battery chemistry

Cycle life

Charging speed

Energy density

Lithium Nickel Manganese Cobalt Oxide.

 

Low

Average

Average

Lithium Nickel Cobalt Aluminum.

 

Average

Average

Average

Lithium Iron Phosphate.

 

High

Average

Low

Lithium Titanate.

 

Very high

Very high

Very low

 

My guess is that we will see the current emphasis on energy density re-balanced or possibly even overtaken by an emphasis on cycle life as EV’s progress through their lives and battery health declines.

 

An emerging battle between wider technologies

 

Pipes & Wires #196 examined gravity storage as a potential competitor for batteries, whilst further competition may come from super capacitors. This can be presented in the following framework…

 

Stored energy

Specific technology

Key features

Primary energy

Gravity

·     Appears to provide longer storage periods (eg. summer to winter).

 

·     Requires significant scale (between 1MW and 20MW) to be cheaper than batteries.

 

Electricity

Batteries

·     Cheaper for small kWh.

 

·     Readily mobile.

 

Capacitors

·     Very rapid discharge time.

 

 

Network regulatory decisions

 

NZ – reducing the allowable annual revenues

 

Introduction

 

The Commerce Commission has recently reconsidered the weighted average cost of capital (WACC) that will apply to the Powerco and Wellington Electricity customised price-quality paths (CPP’s). This article examines the reductions in allowable annual revenue due to resetting the WACC.

 

Context

 

In late 2019 the Commission determined the WACC that will apply for the third default price-quality path (DPP3) starting on 1st April 2020. The regulatory framework (refer below) allows the Commission to reconsider a CPP after the WACC has been determined for a new DPP in order to remove any perverse incentive to apply (or not apply) for a CPP to exploit any material difference between the WACC’s applicable to a DPP and a CPP.

 

Regulatory framework

 

The regulatory framework is set out in clauses 5.6.7(1)(a) and 5.6.7(2)(e) of the Electricity Distribution Services Input Methodologies Determination 2012 (consolidated to 31st January 2019) allows for a CPP to reconsidered after the WACC has been re-determined.

 

The revenue reductions

 

The final decisions set the allowable revenues for the remaining disclosure years of the Powerco CPP and Wellington Electricity CPP to reflect the 25 September 2019 determination of the 67th percentile estimate of WACC for DPP3, viz…

 

 

 

Year ending 31st March

 

 

2021

2022

2023

Powerco

Original MAR

$290.85m

$296.75m

$302.68m

Re-determined MAR

$241.09m

$245.98m

$250.90m

Wellington Electricity

Original MAR

$109.53m

 

 

Re-determined MAR

$91.67m

 

 

 

US – rejecting a smart metering rate case

 

Introduction

 

Regulatory approval of grid modernisation rate cases (regulatory proposals) seems to be very sensitive, especially the smart meter component ... readers might recall one of the first glimpses of this trend in Pipes & Wires #93 when Baltimore Gas & Electric’s smart meter rate case was rejected. This article examines the recent rejection of much of Dominion Energy’s rate case by the Virginia State Corporation Commission.

 

Summary of Dominion’s rate case

 

A quick summary of the rate case is as follows…

 

·     During the 2018 session, the Virginia legislature enacted Senate Bill 966 as the Grid Transformation and Security Act which inter alia deems grid transformation to be in the public interest and requires electric companies to file grid transformation plans for regulatory approval.

 

·     In July 2018 Dominion filed a plan for grid transformation specifically to request approval of additional investment over the first 3 years of the 10 year plan.

 

·     In January 2019 the SCC approved a number of the components of the rate case, referred to as Phase 1A.

 

·     In September 2020 Dominion filed a second petition designated Phase 1B for approval, which is where this story begins.

 

Key components of Dominion’s rate case and the SCC’s decision

 

Key components of Dominion’s rate case and the SCC’s decision include…

 

Component

Dominion proposal

SSC decision

Total

Phase 1B

Advanced metering infrastructure (AMI)

$752.5m

$303.8m

Rejected, reasonableness and prudency not demonstrated.

Cyber security, stakeholder engagement and customer education

$197.7m

$10.4m

Approved as reasonable and prudent.

Customer information platform

$668.9m

$36.5m

Approved as reasonable and prudent.

Pilot programs and hosting capacity analysis

$65.9m

$34.8m

Approved as reasonable and prudent.

Grid hardening

$2,900m

$210.8m

Partially approved as reasonable and prudent, subject to specific requirements.

Self-healing grid and related investments

$2,100m

$241.5m

Rejected, reasonableness and prudency not demonstrated.

 

The decision approves $212m of Phase 1B.

 

The AMI decision in detail

 

A key reason for the SCC’s rejection of the proposed $303.8m AMI spend was the testimony of several witnesses that AMI provides few if any benefits to customers unless accompanied by plans for smarter tariff design, energy efficiency, demand response and integration of DER’s (distributed energy resources). The SCC noted that Dominion’s 1B rate case did not include a comprehensive plan for capturing those benefits, and invited Dominion to re-submit a revised rate case.

 

Aus – the Victorian electricity distribution resets

 

Introduction

 

The five electricity distribution businesses in the Australian state of Victoria have recently started the process of having their revenues reset by the Australian Energy Regulator (AER) for the 5 year regulatory period starting on 1st July 2021. This article examines the Initial Proposals.

 

The regulatory framework

 

The regulatory framework has its basis in s7 of the National Electricity Law, which states the National Electricity Objective which is inter alia to promote efficient investment in electricity services for the long-term benefit of consumers. Chapter 6 of the National Electricity Rules sets out the details for economic regulation of distribution services.

 

Key features of the process to date (AusNet Services)

 

Key features of the process to date include…

 

Parameter

Initial Proposal

($ nominal)

Preliminary Determination

Revised Proposal

Final Determination

Total OpEx

$1,328m

 

 

 

Total CapEx

$1,468m

 

 

 

Opening RAB

$4,715m

 

 

 

Regulatory depreciation

$784m

 

 

 

Unsmoothed revenue

$3,421m

 

 

 

 

Key features of the process to date (CitiPower)

 

Key features of the process to date include…

 

Parameter

Initial Proposal

($ nominal)

Preliminary Determination

Revised Proposal

Final Determination

Total OpEx

$569m

 

 

 

Total CapEx

$690m

 

 

 

Opening RAB

$2,013m

 

 

 

Regulatory depreciation

$403.1m

 

 

 

Unsmoothed revenue

$1,613m

 

 

 

 

Key features of the process to date (Jemena)

 

Key features of the process to date include…

 

Parameter

Initial Proposal

($ nominal)

Preliminary Determination

Revised Proposal

Final Determination

Total OpEx

$577m

 

 

 

Total CapEx

$628m

 

 

 

Opening RAB

$1,551m

 

 

 

Regulatory depreciation

$259m

 

 

 

Unsmoothed revenue

$1,286m

 

 

 

 

Key features of the process to date (Powercor)

 

Key features of the process to date include…

 

Parameter

Initial Proposal

($ nominal)

Preliminary Determination

Revised Proposal

Final Determination

Total OpEx

$1,652m

 

 

 

Total CapEx

$2,312m

 

 

 

Opening RAB

$4,573m

 

 

 

Regulatory depreciation

$760m

 

 

 

Unsmoothed revenue

$3,694m

 

 

 

 

Key features of the process to date (United Energy)

 

Key features of the process to date include…

 

Parameter

Initial Proposal

($ nominal)

Preliminary Determination

Revised Proposal

Final Determination

Total OpEx

$798m

 

 

 

Total CapEx

$945m

 

 

 

Opening RAB

$2,473m

 

 

 

Regulatory depreciation

$593m

 

 

 

Unsmoothed revenue

$2,247m

 

 

 

 

Pipes & Wires will pick up this story again when the AER releases its Preliminary Determinations

 

South Africa – court dismisses Eskom’s request for urgent relief

 

Introduction

 

It’s been a while since Pipes & Wires has examined the follow-on from regulatory determinations. This article notes a High Court dismissal of Eskom’s request for urgent relief from the recent MYPD4 revenue decision.

 

The MYPD4 decision

 

Pipes & Wires #182 and #189 examined Eskom’s MYPD4 revenue control, which is summarised below…

 

Parameter

Eskom’s proposal

NERSA decision

MYPD4 revenue (3 years)

R763b

R661b

Price increase for YE 31st March 2020

15%

9.4%

Price increase for YE 31st March 2021

16.6%

8.1%

Price increase for YE 31st March 2022

16.7%

5.2%

 

Eskom’s request for relief

 

Eskom’s application for relief was two-fold…

 

·     Part A sought a Court Order to allow Eskom to implement a tariff decision prior to the start of the YE 31st March 2021.

 

·     Part B challenged the substance of the MYPD4 decision.

 

A key concern of Eskom’s was NERSA’s treatment of the R23b government injection for each of the 3 years of MYPD4 as revenue.

 

The High Court’s decision

 

The High Court’s ruling was…

 

·     Part A was dismissed, with the High Court arguing that whilst Part A may have merit it was not considered urgent. Significantly, the High Court ruling indicated

 

(i)       that “NERSA violated a basic principle of accounting by treating an equity injection as revenue”, and

 

(ii)     that “the reasonable judgment that NERSA is allowed to exercise cannot translate into an open ended discretion that insulates it from scrutiny and judicial review”.

 

·     That NERSA’s MYPD4 ruling of 7th March 2019 remains for the time being, but is still subject to review as per Part B of Eskom’s application.

 

Next steps

 

Pipes & Wires will examine the High Court’s ruling on Part B as it emerges.

 

Cool multimedia stuff

 

Electricity and its impact in the 1920’s

 

This 3 minute video notes the improvements that electricity bought, particularly the reduction in house fires as the use of kerosene lamps and open fires declined, and the changes in food consumption and grocery buying habits as electric refrigeration spread.

 

Western Power Electricity Historical Society

 

This website has heaps of cool stuff about electricity and electric transport in the south-west of England for the last 120 years … articles, videos, audio casts etc. Thanks to Phil West (ex-WPD) for pointing this out.

 

Energy mix and grid security

 

Aus – possible gas shortages in a few years

 

Introduction

 

Gas-fired generation is expected to play a major role in decarbonising electricity, hence security of both gas fields and pipelines becomes even more important. This article examines the Australian Energy Market Operator’s (AEMO) recently released Gas Statement Of Opportunities (GSOO) for eastern and south-eastern Australia.

 

Regulatory framework for the GSOO

 

The regulatory framework within which the AEMO publishes the GSOO includes…

 

·     The National Gas Law embodying the National Gas (South Australia) Act 2008.

 

·     Part 15d of the National Gas Rules.

 

Key features of the GSOO

 

Key features of the GSOO include…

 

·     The GSOO is based on 3 scenarios of supply and demand, with a central scenario based on market forces under current Commonwealth and state policies. Not surprisingly, these scenarios are strongly linked to electricity events including Snowy 2.0 and the anticipated closure of Liddell.

 

·     The expectation that forecast demand will be met until at least 2023 by existing and committed developments but could require LNG exports to be redirected for domestic use.

 

·     Supply from existing and committed developments could reduce by up to 35% out to 2025. Unless new fields are developed, LNG imports are developed, or transmission pipeline capacity constraints relieved, gas restrictions and even curtailment of gas-fired generation might be required in southern states from 2024.

 

·     Anticipated fields could meet demand out to 2026, however that would require relief of pipeline constraints in Victoria.

 

The editor comments

 

These signaled gas shortages have been a long time coming … Pipes & Wires #162 examined the east coast’s impending gas shortage back in April 2017 in the context of several converging issues…

 

·     Moratoria on various classes of gas exploration within each state (including fracking and coal seam methane).

 

·     Closure of coal-fired generation (at the time Hazelwood and Yallourn W)

 

·     Keeping Tamar Valley open as Tasmania’s best option for securing electricity supply.

 

·     Increasingly constrained transmission pipeline capacity.

 

Regulatory thinking and policy

 

Aus – allowing state-based grid planning

 

Introduction

 

Most of us appreciate the need for large transmission investments to have at least some degree of central coordination. This article examines a recent law change in the Australian state of Victoria that will allow Victoria to override the existing regulatory framework in specific circumstances.

 

Victoria’s concerns

 

The Victorian Government claims that urgently required transmission grid capacity and resilience work to address new renewables and storage, heat-waves, bush fires and extreme weather is being discouraged by the existing NEM regulatory framework, and is unfairly disadvantaging Victorian’s from accessing more reliable, cleaner and cheaper electricity.

 

To this end, it introduced legislation to allow transmission investment to occur outside of the NEM regulatory framework. Whilst this has drawn support from the renewable energy sector, it has also drawn criticism from the Victorian opposition party and from various energy bodies who reiterate that a coordinated inter-state investment framework exists for good reasons, and that the risk of poor investment outcomes for Victoria will increase.

 

The electricity transmission regulatory framework

 

The electricity transmission regulatory framework includes…

 

·     The National Electricity (Victoria) Law 2005, which effectively adopts the National Electricity Law in the state of Victoria.

 

·     The National Electricity Rules, of which Chapter 6A sets out inter alia how new investment must be justified.

 

·     The Electricity Industry Act 2000, which allows the (Victorian) Essential Services Commission to issue electricity transmission licenses.

 

The National Electricity (Victoria) Amendment Act 2020

 

The bill’s explanatory memorandum will allow the Minister to override specific provisions of the NEL and the NER to facilitate or expedite specified transmission augmentations, and to make any necessary transmission license amendments. The key features of the National Electricity (Victoria) Amendment Act 2020 are…

 

·     The introduction of a new Division 7 of Part 3 of the National Electricity (Victoria) Law 2005 to modify the regulatory arrangements for specified declared transmission system augmentations.

 

·     Amending the Electricity Industry Act 2000 to allow the ESC to amend a license or its conditions.

 

·     It will be repealed 12 months after commencement, however any amendments made under this Act will continue.

 

Industry structural changes

 

Global – will decarbonisation strand gas pipelines ?

 

Introduction

 

The major focus of energy decarbonisation seems to be closing coal-fired generation. This article examines some of the emerging trends that could have the less visible result of stranding gas pipelines.

 

Decarbonisation and pipeline stranding

 

The 2 most visible drivers of pipeline stranding appear to be…

 

·     The declining cost of solar generation and batteries, resulting in less gas-fired generation.

 

·     Increasing restrictions on the use of natural gas as a heating and industrial fuel.

 

An increased role for gas-fired generation ?

 

We are seeing increasing arguments for gas as a transition fuel as most of the worlds’ electricity systems migrate from coal to renewables, with a key issue being the integration of variable renewable generation. Some issues to consider include…

 

·     How well variable renewables can be integrated in practice.

 

·     How much further the costs of solar and batteries will decline.

 

·     Whether electricity markets will correctly signal price volatility to a level that encourages gas-fired generation (and I’m not an expert on the detail of electricity markets, so will defer to others on that).

 

The emerging hydrogen economy

 

Any forecasts of where a hydrogen economy might go are probably very premature, with much more research needed on the costs of actually making and using hydrogen. However it does hold at least some promise for the gas pipeline industry.

 

Recent client projects

 

Recent client projects include…

 

·     Compiling a pricing model to reflect asset investment levels to transmission grid exit level rather than averaged over the entire network.

 

·     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.

 

House-keeping stuff

 

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Disclaimer

 

These articles are of a general nature, they do not constitute 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 contents of Pipes & Wires including any loss, damage or exposure to offensive material from linking to any websites contained herein, or from any republishing by a third-party whether authorised or not, nor from any comments posted on Linked In, Face Book or similar by other parties.