Pipes & Wires

Though leadership of critical energy & infrastructure matters

Issue 201 – October 2020

 

From the editor’s desk…

 

Welcome to Pipes & Wires #201 … this issue starts with a look at the recent downgrading of NZ’s gas reserves, followed by a look at the task force report on the closure of Liddell Power Station in Australia. We then look at a controversial regulatory decision favoring fixed monthly charges for rooftop solar customers in the US.

 

We then examine 3 pipes & wires regulatory decisions in the UK, NZ and Australia respectively and conclude with 2 industry ownership reshufflings in the US. So … until next month, happy reading…

 

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Recent client projects

 

Recent client projects include…

 

·     Estimating the costs of DERMS (distributed energy resource management system) penetration for distribution feeders for a large US electric company.

 

·     Identifying leading practices in behind-the-meter activities (eg. batteries, solar, smart data, VPP’s etc) for a large US electric company.

 

·     Identifying key learnings from the transformation of a Dutch electric, gas and heat company for a large US electric company.

 

·     Identifying best Australian practices in EV charging for a large US electric company.

 

·     Identifying key features of demand management in the Australian NEM for a large US electric company.

 

·     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.

 

Cool multimedia stuff

 

CEGB Midland Region website

 

Any readers who worked for the CEGB in the 1960’s might be interested in the CEGB Midland Region website.

 

Asset management and asset strategy podcasts

 

My colleagues at the UMS Group have put together a series of podcasts on asset management and asset strategy, including an interview with me on how to make asset management happen in small companies. This has also been republished as a short narrative.

 

Energy mix and grid security

 

NZ – gas under pressure

 

Introduction

 

Readers might remember the downgrading of the Maui gas fields’ expected remaining reserves back in 2005. This article examines the much more recent downgrading of the Pohokura gas fields’ expected remaining reserves.

 

The recent Pohokura downgrade

 

Pohokura’s estimated recoverable reserves were recently reassessed downwards by about 217 PJ in early 2020. To provide some useful context, NZ’s annual gas consumption is about 180 PJ (of which Pohokura supplies about 40%), so that downgrade represents about 14½ months consumption. Fortunately other gas fields have been reassessed upwards, as follows…

 

·     Mangahewa (52 PJ)

 

·     Kapuni (54 PJ).

 

·     Turangi (65 PJ).

 

·     Kupe (30 PJ).

 

·     Maui (38 PJ).

 

So these upgrades totaling 239 PJ give a nett increase of about 1½ months gas supply.

 

The wider gas supply scene

 

As at January 2020, NZ’s proven gas reserves were about 2021 PJ, or about 11¼ years supply at current consumption rates. A quick scratch up of some approximate numbers for comparison is as follows…

 

Country

Reserves (km3)

Annual consumption (km3)

Expected supply (years)

Russia

47,805

444

108

Iran

33,721

223

151

US

15,484

846

18

China       

5,444

307

17

NZ

66

5

13 (close enough to 11¼)

 

So while NZ is not alone in having just over a decade’s indigenous gas supply, that’s not long in terms of finding and developing new supplies especially if gas is going to be the transition fuel.

 

Aus – the Liddell closure taskforce reports back

 

Introduction

 

Pipes & Wires #192 and #196 examined the Government task force that was established to examine the intended closure of the 4 x 500 MW coal-fired Liddell Power Station in the Hunter Valley of New South Wales. This article examines the final report and the Government’s response.

 

Recapping the previous work

 

On the back of AGL’s intended closure of Liddell in 2022 (later extended to 2023), Pipes & Wires #192 noted the establishment of the task force and that a particular concern was wholesale price spiking and security decline in the NEM similar to when Hazelwood closed. Pipes & Wires #196 examined the draft report which noted that…

 

·     Liddell’s life could be extended by a further 3 years to 2026, at an apparent cost of $300m, but it would still be likely to prove unreliable, and hence should not be relied upon.

 

·     Life extension of Liddell could curb gas expansion projects such as Tallawarra B.

 

·     It is expected that this life extension would need to be taxpayer funded, as AGL has previously indicated that it is unwilling to fund life extension.

 

·     That pumped storage, gas and batteries could feasibly replace Liddell.

 

The final report

 

The task force delivered its final report in April 2020, which included a wide range of conclusions and recommendations. Taken in aggregate, the broad conclusions are…

 

·     Wholesale prices would rise about $5 per MWh to $10 per MWh more than they otherwise might.

 

·     Publically announced battery and generation projects will more than offset the loss of system reliability, but a decline in grid security may still emerge.

 

Key recommendations include…

 

·     That a policy framework to address the reliability impact of coal closures be developed through the COAG Energy Council (there seems to be at least some nervousness about the price and security impacts of closing Liddell, based in part at least on the observations of closing Hazelwood).

 

·     That non-market barriers to developing replacement generation must be dismantled.

 

·     That demand response and DER integration be used as a short-term response to the MWh gap.

 

As always, interested parties should read the full report.

 

The Government’s response

 

Key features of the Government’s response (released in September 2020) include…

 

·     A clear statement that the observed price increases and security decline arising from the Hazelwood closure have not been addressed for the Liddell closure, and that further price rises and security declines are unacceptable.

 

·     Setting a target of 1,000 MW of dispatchable generation to be developed by the private sector for the 2023/24 summer.

 

·     Continued support of new gas-fired generation.

 

·     Signaling government intervention if private sector commitment have not emerged by April 2021. This includes private-sector life extension of Liddell, but stops short of Government funding for a Liddell life extension.

 

This is obviously a significant energy trilemma issue, so Pipes & Wires will comment further as news emerges.

 

Regulating emerging technologies

 

US – regulator upholds “sun tax”

 

Introduction

 

The idea that fixed monthly charges are a “tax” on solar seems to be one of the well-established themes of the ideological battle between rooftop solar and electric distribution companies. This article notes a recent decision by the Alabama Public Service Commission to not only uphold Alabama Power’s solar tariff, but to increase it.

 

Alabama Power’s solar tariff

 

Alabama Power currently charges an additional $5 / kW / month to connect rooftop solar to its network, hence a customer with a 5kW panel would pay an additional $25 per month. This is referred to as a capacity reservation fee, or a firm back-up fee.

 

Challenges to the tariff

 

Various groups opposed that tariff, which led to the Southern Environmental Law Center (SELC) petitioning the Alabama Public Service Commission (APSC) back in 2018 to prohibit Alabama Power from charging a solar tariff, claiming that it reduces the benefit of rooftop solar (which it undoubtedly does, and which electric companies have never denied).

 

Alabama Power in turn asked the APSC to (i) dismiss the petition, and (ii) allow the tariff to be increased to $5.42 / kW / month, claiming that the existing $5 / kW / month was insufficient to offset the reduced kWh revenue.

 

The APSC decision

 

In a 3 – 0 decision, the APSC not only voted to dismiss the petition, but to allow Alabama Power to increase its solar tariff to $5.41 / kW / month.

 

The various views on the decision

 

The various views on the decision have fallen into a fairly predictable pattern…

 

·     The various solar and environmental have criticized the decision, claiming that it is a regressive step for Alabama, out-of-step with other states policies, and that the APSC along with Alabama Power continue to prevent the transition to cleaner energy.

 

·     Alabama Power in turn reiterates its argument that rooftop solar customers who want the security of grid connection need to pay for that connection.

 

Network regulatory decisions

 

UK – National Grid responds to RIIO – T2 draft

 

Introduction

 

Pipes & Wires #200 examined Ofgem’s draft RIIO – 2 price controls that will apply to inter alia National Grid for the 5 year period starting on 1st April 2021. This article firstly notes National Grid’s public response to the draft, and then considers the wider aspect of balancing price and supply quality.

 

National Grid’s concerns

 

National Grid had proposed about £10b of electricity and gas transmission investment focused on long-term resilience and nett-zero CO2 transition, and has expressed concern that the RIIO – 2 draft rejected 50% of the proposed electricity investment and 40% of the proposed gas investment. That 50% cut of electricity investment includes an 80% cut in the proposed £3b reliability spend, which National Grid estimates will increase the risk of asset failure by about 24% and require anything up to 100 years to replace aging assets.

 

National Grid has cited the specific example of replacing 1 of the 2 cables supplying Sheffield at a cost of £40m, due to deterioration. In turn, Ofgem has commented that 1 condition assessment dating from 2015 is insufficient to justify this project (and if that is in fact correct, I would be inclined to agree).

 

Ofgem also notes that it is providing regulated suppliers with the opportunity to strengthen the business cases for such projects.

 

Wider aspects of balancing price and supply quality

 

Balancing price and supply quality is obviously an issue of national importance that should be evident to all, with the consequences of getting it wrong running into billions of pounds.

 

Without a doubt, blackouts in general seem to be occurring more frequently, but in this context we need to be focused solely and narrowly on those blackouts caused by lack of replacement spend caused by excessive price cuts. What is concerning is that 2 very knowledgeable organisations have come up with such significantly different answers (and that is not to say that this has never occurred before, but it is none-the-less concerning).

 

Next steps

 

Pipes & Wires will comment further when Ofgem releases its final decisions around December 2020.

 

NZ – WE* draft transition back to a DPP

 

Introduction

 

The regulatory framework for electricity distribution businesses that do not meet the customer ownership requirements set out in s54D of the Commerce Act 1986 provides for default regulation by a default price-quality path (DPP), or a customised price-quality path (CPP) if the business believes that the allowable DPP revenue is insufficient. This article examines the Commerce Commission’s recently published draft decision for Wellington Electricity’s (WE*) transition back to a DPP when its CPP ends on 31st March 2021.

 

Key features of the WE* CPP

 

WE* is subject to a 3 year CPP, concluding on 31st March 2021. Key features of the WE* CPP include…

 

·     A starting price of $105.206m.

 

·     A rate of change of CPI – 0%.

 

·     A maximum SAIDI of 40.63 for each of the 3 years.

 

·     A maximum SAIFI of 0.625 for each of the 3 years.

 

·     Have a minimum resilience index of 20, 40 and 60 for each of the 3 years (which specifically relates to improving earthquake resilience to a New Building Standard of 67%).

 

The transition back to the DPP

 

The WE* CPP ends on 31st March 2021, after which a 4 year DPP will apply to align with the current 5 year DPP period ending on 31st March 2025.

 

The draft decision

 

Key features of the draft decision include…

 

·     Setting the 1st April 2021 starting price using a building blocks approach rather than simply rolling over the CPP closing price. This is similar to the approach used to compile the current DPP3 revenue control.

 

·     Approving an adjustment to the base year OpEx based on the 2021 earthquake readiness spend approved in the CPP determination, instead of the 2020 actual spend.

 

·     Not approving an adjustment to the base year OpEx based on 2021 insurance premiums.

 

Next steps

 

Consultation on the draft decision has now closed, and the Commission expects to publish its final decision in late November 2020. Pipes & Wires will comment further when that final decision emerges.

 

As always, interested parties should read the full decisions documents.

 

Aus – the draft AA5 decision for the Dampier – Bunbury pipeline

 

Introduction

 

It’s been a while since Pipes & Wires has examined any of the major Australian gas transmission pipelines. This article examines the draft decision for the Fifth Access Arrangement (AA5) for the Dampier – Bunbury Natural Gas Pipeline to set some context for the final decision.

 

A bit about the DBNGP

 

The DBNGP is a 660mm welded steel pipeline stretching approximately 1,600km, to link the Carnarvon Basin gas fields via Dampier to Perth and Bunbury. The pipeline was built in 1984, and includes 27 compressor units at 10 locations. The current owner of the pipeline is DBNGP (WA) Transmission Pty Ltd.

 

The regulatory framework

 

The DBNGP is 1 of 3 gas transmission pipelines regulated by the Economic Regulation Authority (of Western Australia). The regulatory framework includes…

 

·     The National Gas (South Australia) Act 2008.

 

·     The National Gas Rules.

 

·     The National Gas Access (WA) Act 2009.

 

The decision process to date

 

The decision process to date includes…

 

·     January 2020 – DBNGP submitted its proposed revisions to its original AA5 proposal.

 

·     August 2020 – ERA published its draft decision to (i) not approve the AA5 proposal, and (ii) require 53 amendments.

 

·     October 2020 – DBP submitted a revised (revised) AA5 proposal.

 

Next steps

 

Pipes & Wires will comment further when the ERA releases its final decision.

 

Industry reshuffling

 

US – the price of becoming a muni

 

Introduction

 

Pipes & Wires #192 examined Chicago’s proposed municipalising of Commonwealth Edison (ComEd) when its’ franchise expires on 31st December 2020. This article examines the key conclusions of the feasibility study.

 

Recapping the ComEd situation and the muni proposal

 

ComEd has supplied electricity to Chicago under a franchise agreement since 1947, and which was last renewed in 1992 for a 29 year period. The agreement includes a monthly franchise fee paid to the City, which along with electricity taxes generates about $183m per year for the City.

 

A key element of the muni proposal is that Chicago has an opportunity to define its energy future … it was claimed that through municipalisation, Chicago could accelerate decarbonisation and implement a progressive tariff structure that ensures better prices for working-class Chicagoans. Pipes & Wires noted that in broad terms, it was hard to see how a simple change of ownership would allow a significant repositioning of ComEd on the energy trilemma.

 

Key conclusions of the muni study

 

Readers will recall that Chicago commissioned NewGen Strategies And Solutions to estimate the costs of municipalising ComEd. Key conclusions of that study include…

 

·     That the average annual electric rate would be greater for a muni than it would under the existing ComEd franchise for the period 2020 to 2039.

 

·     An estimated asset purchase cost of about $4.9b.

 

·     An estimated cost of separating the ComEd network from parent company Exelon of about $3.9b (mainly additional transmission and distribution assets, and metering).

 

·     A view that it would take many years to establish a muni and get it to the point where it could actually start achieving Chicago’s stated goals.

 

So municipalisation of ComEd would cost Chicago about $8.8b.

 

The editor comments

 

Chicago’s mayor has somewhat cryptically commented that “municipalising does not appear to be financially feasible”, which is probably no surprise to most of us. Pipes & Wires commented a few editions ago that municipalisation could be a serious case of “be careful what you wish for”, and it seems that has been borne out.

 

US – the first of the mega-mergers gets rejected

 

Introduction

 

Pipes & Wires has examined many mergers of US electric companies that cost around $10b to $15b. This article examines Next Era Energy’s recently rejected merger with Duke Energy with an estimated value of $60b, and considers whether this might set the scene for a wave of mega-mergers of the already-big electric companies. 

 

A bit about Next Era and Duke

 

NextEra Energy owns about 46,000 MW of generation, and supplies over 5,000,000 customers in 16 states and Washington DC. Annual revenues are about $19b, nett income is about $3.4b, and total assets are about $118b.

 

Duke Energy owns about 51,000 MW of generation, and supplies 7,700,000 electric customers in North Carolina, South Carolina, Florida, Ohio, Kentucky and Indiana, and 1,600,000 gas customers in North Carolina, South Carolina, Ohio, Kentucky and Tennessee. Annual revenues are about $25b, nett income is about $2.1b, and total assets are about $159b.

 

The merged company would therefore have had about 97,000 MW of generation, and supply 12,700,000 electric customers and 1,600,000 gas customers in 21 states and Washington DC. Annual revenues would’ve been about $44b, nett income would’ve been about $5.5b, and total assets would’ve been about $277b. The market capitalisation of about $200b would’ve been far above the next largest electric companies (Dominion Energy at $65b, and Southern Company at $57b).

 

The proposed deal

 

No details of the deal structure appear to have been made public, other than it was proposed as a “merger”, however the rise in Duke’s stock price suggested that its shareholders favored some sort of amalgamation. In any case Duke swiftly rejected NextEra’s approach, to which NextEra responded that it would not pursue a hostile takeover.

 

Key issues

 

The following issues would’ve made the merger tough work…

 

·     Duke’s 15,000 MW of coal-fired generation being seen as inconsistent with NextEra’s emphasis on renewables.

 

·     The need for an overwhelming number of regulatory approvals … 20+ state regulators, the Federal Energy Regulatory Commission, the Securities & Exchange Commission and possibly the Federal Communications Commission, the Nuclear Regulatory Commission and the Department Of Justice.

 

·     Possible dilution of NextEra’s industry-leading price-to-earnings multiple of 28.

 

·     NextEra’s recently failed merger attempts with Oncor Electric Delivery (2016) and Hawaiian Electric (2017).

 

So although this merger was rejected in the first instance, it may well have sown the seed for the other already-big electric companies to think about merging.

 

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.