Pipes & Wires

Though leadership of critical energy & infrastructure matters

Issue 212 – March 2022

 

From the editor’s desk…

 

Welcome to Pipes & Wires #212 …. this issue starts with a quick look at my recent climate resilience and governance work, and then examines two regulatory decisions in New Zealand and Australia. We then look at some industry reshuffling, with one in particular focusing on the clean energy transition.

 

We then examine the Input Methodologies review in New Zealand, and examine some energy mix and grid security issues in Australia and conclude with a look at solar curtailment in Western Australia.

 

A recurring theme of this issue is the increasing need for orderly retirement of thermal generation. My colleagues at the UMS Group have extended their successful learning consortia program with the Glidepath For Coal learning consortium for electric companies to share their learnings and best practices in a secure and confidential forum.

 

So … until next time, happy reading…

 

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Recent client projects

 

Recent climate resilience and governance client projects include…

 

·       Aligning an electric company’s governance framework to the Taskforce on Climate-related Financial Disclosure (TCFD) recommendations.

 

·       Compiling a TCFD reporting framework for an electric distribution company.

 

·       Translating climate policy into infrastructure asset management practices.

 

·       Linking an electric distribution company’s asset management practices to climate predictions.

 

·       Identifying leading global practices for electric company climate resilience, including developing specific asset strategies.

 

·       Assisting 2 electric companies to identify the revenue growth opportunities as decarbonisation creates new markets for energy services.

 

·       Amending risk management frameworks to include climate risk identification, quantification and mitigation.

 

·     Identifying emerging best practices for community-scale and grid-scale batteries for an Australian lines company.

 

·       Advised an Australian electric company on how the Regulator has treated network transformation expenditure.

 

·       Identifying best practices in EV charging for an Australian lines company, including likely regulatory treatment of chargers.

 

·       Compiled an EV charging strategy including estimates of the number of EV’s, likely charging habits and possible tariff options.

 

·       Compiling a solar PV market intelligence report for an EDB.

 

·       Compiled a regulatory submission on proposed regulatory settings for DER’s on behalf of an EDB.

 

·       Identifying the key features of distributor-led transition from a DNO to a DSO or DMO.

 

·       Assess solar PV investment opportunities on behalf of a private investor.

 

·       Identified emerging practices in DER integration.

 

·       Compiled a regulatory submission on EV charging on behalf of an EDB.

 

·       Advised a US electric company on the role that demand aggregators are playing in the Australian NEM, and how that demand aggregation might defer distribution feeder investment.

 

·       Advised a US electric company on Australian best practices in EV charging, including what value streams are available.

 

·       Advised a US electric company on which Australian electric companies have the best behind-the-meter practices.

 

·       Advised a US electric company on the likely costs of DER integration based on recent Australian regulatory proposals.

 

·       Advised a US electric company on how DERMS in NZ and Australia are altering CapEx and OpEx requirements.

 

These are in addition to Utility Consultants asset management, risk mitigation and regulatory strategy work.

 

Cool multimedia stuff

 

Cool video clip – 115 year old substation

 

This 20 minute video clip examines the early beginnings of fragmented electricity supply in Britain, including the technical challenges of interconnecting supplies with different frequencies.

 

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.

 

Bruce Springsteen cover … back by popular demand…

 

Back by popular demand … pick this link to see my awesome daughter Becca Caffyn singing Bruce Springsteen's "Dancing In the Dark" off the 1984 album Born In The USA.

 

Network regulatory decisions

 

NZ – the draft gas DPP3

 

Introduction

 

Pipes & Wires #208 noted the Commerce Commission’s preliminary work on the third gas default price-quality path (gas DPP3) that will apply to the 4 gas distribution businesses and the 1 gas transmission business for the 5 year period starting on 1st October 2022. This article examines the Commission’s recently released draft decision to provide some context for examining the final decision.

 

Regulatory framework

 

The regulatory framework is set out in Part 4 of the Commerce Act 1986, and includes…

 

·       Subpart 6, which sets out the generic default and customised price-quality regulation.

 

·       Subpart 10, which includes regulatory issues specific to gas pipelines.

 

Key features of the draft gas DPP3

 

Key features of the draft gas DPP3 include…

 

·       Adoption of a 4 year regulatory period (the minimum allowed by the Commerce Act 1986).

 

·       Accelerated depreciation to provide certainty of cost recovery.

 

·       Changes to the WACC.

 

Specific parameters of the draft DPP3

 

Specific parameters of the draft DPP3 include…

 

Parameter

Draft decision

Final decision

WACC

6.07%

 

Average domestic bill increase per year

$55

 

Total revenue - GasNet

$21.89m

 

Total revenue - Powerco

$282.24m

 

Total revenue - Vector

$261.84m

 

Total revenue – First Gas (distribution)

$135.88m

 

Total revenue – First Gas (transmission)

$713.48m

 

 

Next steps

 

The Commission expects to publish its final decisions around the end of May 2022, after which Pipes & Wires will conclude this article.

 

Aus – the ElectraNet revenue determination

 

Introduction

 

ElectraNet recently submitted its Regulatory Proposal (rate case) to the Australian Energy Regulator (AER) for the 5 year control period commencing on 1st July 2023. This article examines the key features of that Proposal to set some context for examining the AER’s draft and final decisions.

 

A bit about ElectraNet

 

ElectraNet owns and operates the high voltage transmission grid in South Australia, comprising 5,600km of 275kV, 132kV and 66kV circuits along with 91 grid substations. ElectraNet is owned by State Grid Corporation Of China, YTL Power investments and the Utilities Trust Australia.

 

Regulatory framework

 

The basis of the regulatory framework is Chapter 6a of the National Electricity Rules, which is made pursuant to the National Electricity Law.

 

Key features of the process to date

 

Key features of the ElectraNet process to date include…

 

Parameter

Proposal

Draft Determination

Revised Proposal

Final Determination

CapEx

$742m

 

 

 

OpEx

$571m

 

 

 

Opening RAB

$3,594m

 

 

 

Post-tax nominal WACC

4.29%

 

 

 

Depreciation

$341m

 

 

 

Smoothed revenue

$1,709m

 

 

 

 

Pipes & wires will comment further once the AER releases its Draft Determination.

 

Industry reshuffling

 

US – refocusing on clean energy

 

Introduction

 

Pipes & Wires #206 noted that after 25+ years of mergers to unlock value, the unlocking of value has now turned to demergers. This article briefly recaps the trends, and looks at Dominion Energy’s exit from its gas businesses, ostensibly to migrate that capital into renewable electricity businesses.

 

The pattern of mergers and de-mergers

 

The following pattern of de-mergers has emerged…

 

Pattern

Objective

Legacy mergers and acquisitions focused on horizontal aggregation between similar companies, in part due to prohibitions on vertical re-integration in many jurisdictions.

 

Primarily to increase scale (and in some cases, scope) efficiencies. In some cases the amalgamation gains were captured for a limited period, and were then shared with customers after the next reset.

 

Vertical de-mergers began in which early-movers recognised the increasingly different investment characteristics of (regulated) lines and (unregulated) energy. A lot of these vertical de-mergers happened in Germany around 2009.

 

Separate businesses having different risk and reward profiles eg. pension funds seem to prefer regulated lines businesses.

Shifted to include horizontal demergers as the differing investment characteristics of fossil, hydro, wind and solar generation become more apparent. TrustPower’s demerging of its hydro and wind businesses to form Tilt Renewables back in 2016 is a good example.

 

Further separate energy businesses having different risk and reward profiles.

 

A bit about Dominion Energy

 

Dominion Energy supplies 7,000,000 energy customers across 13 states, with annual revenues of $14b.

 

Dominion Energy’s reshaping

 

Over the last few months Dominion has sold the following gas businesses…

 

·       Hope Gas, to Ullico for $690m.

 

·       Questar Pipelines, to Southwest Gas Holdings for $2b

 

Key components of Dominion’s strategy include…

 

·       Reducing the business’ overall risk exposure.

 

·       Recycling capital into attractive regulated businesses.

 

This refocusing on regulated electricity is expected to result in about 85% of Dominion’s earnings coming from regulated businesses.

 

Further reading

 

·       Pipes & Wires #209 – Aus – AGL Energy proposes demerger.

 

·       Pipes & Wires #207 – NZ – Mercury enters binding agreement to acquire Trustpower’s retail business.

 

·       Pipes & Wires #206 – Global – demergers in the quest for value.

 

·       Pipes & Wires #205 – Exelon plans to separate generation into second company.

 

·       Pipes & Wires #114 – Germany – EnBW looks to sell majority stake in transmission grid.

 

·       Pipes & Wires #88 – E.On sells EHV grid to TenneT.

 

·       Pipes & Wires #86 – Germany – unbundling the grid.

 

Aus – AGL rejects takeover bid

 

Introduction

 

Australia has seen a couple of big infrastructure plays recently … Spark Infrastructure, AusNet Services and Sydney Airport. This article examines AGL’s recent rejection of a takeover bid by Brookfield Asset Management and Atlassian.

 

A bit about AGL

 

AGL began as the Australian Gas Light Company in Sydney in 1837, and listed on the Sydney Stock Exchange sometime around 1871. From those simple beginnings, AGL has grown into an integrated energy services company supplying 4,200,000 electric and gas customers and operating a portfolio of coal and renewable generation totalling almost 11,000 MW (which supplies about 20% of the National Electricity Market).

 

AGL expects its proposed demerger to be completed by 30th June 2022.

 

The offer

 

The unsolicited all-cash offer of $7.50 per share represented a 4.7% premium to AGL’s last closing price, and valued AGL’s equity at $4.9b. It is understood that the bidding consortium planned to abandon AGL’s proposed demerger and to close AGL’s remaining coal-fired stations (Bayswater, Liddell and Loy Yang) 15 years ahead of schedule.

 

AGL’s rejection of the offer

 

AGL roundly rejected the offer, publically stating that…

 

·       It does not offer an adequate premium for a change of control.

 

·       It is not in the best interests of AGL shareholders.

 

·       It would forego the opportunity to realise the value of the proposed demerger.

 

·       It could delay decarbonisation

 

Further reading

 

·       Pipes & Wires #209 – Aus – AGL Energy proposes demerger.

 

·       Pipes & Wires #208 – Spark Infrastructure accepts takeover offer.

 

·       Pipes & Wires #201 – Aus – the Liddell closure task force reports back.

 

Regulatory policy

 

NZ – reviewing the Input Methodologies

 

Introduction

 

Regulatory regimes aim to give certainty to regulated suppliers and their investors, with a large part of that certainty being a pre-defined approach to setting many of the numerical parameters embedded in regulatory decisions. This article examines the Commerce Commission’s commencement of its review of the Input Methodologies.

 

Regulatory framework

 

The regulatory framework for the Input Methodologies (IM’s) is set out in Subpart 3 of Part 4 of the Commerce Act 1986, with s52V setting out the Commission’s required process and s52Y requiring a review of each IM at intervals of no more than 7 years.

 

Key features of the Commission’s Notice Of Intent

 

Key features of the Notice Of Intent include…

 

·       The IM’s will cover airports, electricity distribution, Transpower, and gas pipelines.

 

·       Setting out the proposed process, including consultations on decision making framework and a Process & Approach Paper (Quarter 2 of 2022), through to an expected Final Report in Quarter 4 of 2023.

 

Pipes & Wires will comment further as work progresses.

 

The wider view

 

The Commission’s Cover Letter notes that work by other agencies such as the Climate Change Commission and the Infrastructure Commission form part of the wider of context of the electricity distribution IM’s.

 

 

 

Energy mix and grid security

 

Aus – early closure of Eraring

 

Introduction

 

Closing coal-fired power stations in Australia has been a recurring theme of Pipes & Wires. This article examines Origin Energy’s recently announced closure of the Eraring coal-fired station on the New South Wales central coast.

 

A bit about Eraring

 

Earing has 4 black coal fired steam turbines that were originally rated at 660MW, but which were upgraded to 720MW each in 2012 and 2013. Construction started in 1977, with the first unit being synchronised in 1982.

 

Origin’s plans for Eraring and beyond

 

Origin had originally planned to close Eraring in 2032 but has now bought that closure forward to August 2025, noting that cheap wind and solar have hollowed out the market for inflexible coal generation. Origin intends to install a 700MW battery on the Eraring site, and notes that the NSW Government plan to install a 1,400MW battery in the Hunter Valley.

 

The energy trilemma implications

 

The planned withdrawal of 2,880MW of firm capacity from the National Electricity Market (NEM) will certainly have implications for the energy trilemma, although opinions vary…

 

·       Security - opinion seems to vary on whether grid security in the NEM will decline, however an official statement from the Australian Energy Market Operator (AEMO) notes that planned additional transmission grid capacity and the announced battery will meet the Energy Security Target at the time of the proposed closure.

 

·       Price – opinion seems more uniform that some price spiking in the NEM may occur. Commentators note, however, that the 3½ year notice period should give the market sufficient time to adjust (unlike the 6 month notice of the Hazelwood closure back in 2017 that did cause price spiking).

 

Further reading

 

·       Pipes & Wires #208 – Aus – future energy scenarios

 

·       Pipes & Wires #207 – Aus – closing coal-fired generation

 

·       Pipes & Wires #201 – Aus – the Liddell closure task force reports back

 

·       Pipes & Wires #196 – Aus – the draft Liddell Task Force report.

 

·       Pipes & Wires #193 – Aus – increasing concern over coal-fired closures.

 

·       Pipes & Wires #193 – Aus – examining the impact of the planned Liddell closure.

 

·       Pipes & Wires #191 – Aus – closing coal-fired generation.

 

·       Pipes & Wires #180 – Aus – coal makes a comeback.

 

Aus – reconciling new thermal with decarbonisation

 

Introduction

 

Most energy scenarios and forecasts don’t include new thermal generation. This article examines the recent approval of a 600MW gas-fired plant in the Australian state of New South Wales (NSW), and identifies a range of issues to ponder.

 

Approval of gas-fired generation

 

In December 2021, the NSW Government approved Snowy Hydro’s application to build a 600MW open-cycle gas turbine station at Kurri Kurri in the Hunter Valley. A key argument for Kurri Kurri is improving security of supply in the NEM as Liddell closes in 2023 and renewables ramp up. Snowy will be required to provide the NSW Government with a nett-zero generation plan that may include firing Kurri Kurri on (presumably Green) Hydrogen.

 

Agency scenario – Transgrid’s Energy Vision

 

Back in October 2021, Transgrid released its Energy Vision, which set out the following six scenarios for the NEM out to 2050…

 

·       Current trends – aging coal stations are replaced with competitively priced large-scale and small-scale renewables and storage.

 

·       Deep decarbonisation – market forces, politics and customer expectations converge to drive huge emission reductions.

 

·       Prosumer power – customer choices and technology advances drive a high penetration of well-coordinated DER’s.

 

·       Deindustrialisation death spiral – a global economic recession causes 50% decline in industrial electricity consumption and a 10% decline in commercial electricity consumption.

 

·       States go it alone – breakdown in NEM regulations and regulatory impasses results in state-based silo policies and no new interstate transmission.

 

·       Clean energy superpower – leverage of renewables and mineral ores to export green hydrogen and metals.

 

These six scenarios each embody different mixes of decentralisation and decarbonisation.

 

Agency scenario - the AEMO’s Draft 2022 Integrated System Plan

 

More recently, in December 2021, the Australian Energy Market Operator (AEMO) published its Draft 2022 Integrated System Plan (ISP). The ISP sets out four scenarios…

 

·       Slow change – challenging economic environment, with greater risk of deindustrialization but also slower emissions reduction that would fail to reach Australia’s decarbonisation goals.

 

·       Progressive change – progressive pursuit of emissions reduction, with a ratcheting up of the targets over time.

 

·       Step change – rapid and nationally coordinated customer-led energy transformation.

 

·       Hydrogen superpower – quadrupling of electricity consumption to support a global hydrogen export industry, underpinned by significant technology shifts in transport and manufacturing.

 

The AEMO expects that the step change scenario is the most likely to occur (readers might recall that these four scenarios are similar to the five scenarios set out in AEMO’s final 2021 Inputs, Assumptions & Scenarios Report.

 

Making sense of the Kurri Kurri approval

 

Key issues for us all to ponder include…

 

·       None of the ten agency scenarios examined consider increased thermal generation. This could result in the states go it alone scenario emerging.

 

·       Critics claim Kurri Kurri will increase prices in the NEM. In all fairness, many price trajectories suggest that renewables plus storage are already on a price parity with gas turbines.

 

·       The idea of firing Kurri Kurri on (green) Hydrogen would require an established Hydrogen supply industry, which still seems uncertain.

 

·       Has the “gas as a transition fuel” argument had its day ?

 

·       What if emerging renewables prove less reliable than thought, and security does decline significantly when Liddell closes (as it did when Hazelwood closed).

 

Further reading

 

·       Pipes & Wires #209 - Global – could hydrogen-fired gas turbines beat batteries.

 

·       Pipes & Wires #201 - Aus – the Liddell closure task force reports back.

 

·       Pipes & Wires #188 - US – what future hath gas turbines.

 

·       Pipes & Wires #175 - Aus – prices rise as Hazelwood exits the NEM.

 

Regulating emerging technologies

 

Aus – solar curtailment in the West

 

Introduction

 

Curtailing solar exports to maintain network and grid stability appears to be a controversial theme. This article examines the recent introduction of distributed generation management in Western Australia.

 

Why is curtailment controversial ?

 

There appear to be a couple of reasons that curtailment of solar is controversial…

 

·       It effectively wastes free solar energy.

 

·       It reduces the feed-in revenue paid to solar owners.

 

Options for export curtailment

 

Options for export curtailment include (sort of in ascending order of contribution to network and grid stability)…

 

·       Static export limits – preprogrammed export limit set by the network operators’ understanding of available network capacity. In some cases this export limit will be zero, effectively preventing any export and limiting solar generation to behind the meter consumption.

 

·       Automated inverter settings – sensing of the immediately surrounding LV network voltage with respect to a preprogrammed voltage, but with no sensing of wider grid congestion.

 

·       Dynamic operating envelopes – a progression of static export limits, in which allowable solar export can be set by dynamic models that reflect network and grid status.

 

·       Economic curtailment – curtailing export in relation to price signals rather than congestion and stability signals, which can include curtailing export if prices go negative (ie. costs to export).

 

·       Distributed generation management – sensing the wider network and grid congestion and stability, and continuously adjusting allowable solar exports.

 

The WA scheme

 

The recently introduced Emergency Solar Management Requirements require all new or upgraded solar panels in Western Australia to include sufficient functionality to curtail export when grid demand reaches critically low levels. These requirements coincide with Western Power’s pilot Project Symphony will evaluate the behavior and performance of 900 DER’s.

 

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.

 

Extending the above, a second collection of classic historical photo’s with humorous captions looks at some topical issues of regulating emerging technologies. 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.