Benefits Determination and Cost Allocation

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Benefits Determination and Cost Allocation Johannes Pfeifenberger Transmission Executive Forum West 2012 Meeting Public Policy Objectives through Transmission Investment San Diego, CA October 22, 2012 Copyright 2012 The Brattle Group, Inc. www.brattle.com Antitrust/Competition Commercial Damages Environmental Litigation and Regulation Forensic Economics Intellectual Property International Arbitration International Trade Product Liability Regulatory Finance and Accounting Risk Management Securities Tax Utility Regulatory Policy and Ratemaking Valuation Electric Power Financial Institutions Natural Gas Petroleum Pharmaceuticals, Medical Devices, and Biotechnology Telecommunications and Media Transportation

Transmission Investment and Replacement Needs High current transmission additions still well below 40-50 years ago, when much of the current grid was built 10,000 [1]: EEI (>132kV) [2]: NERC (>200kV) 8,000 [3]: Ventyx (>200kV) Projected Transmission Additions from NERC under Form EIA-411 (>200kV) Projected Transmission Additions from NERC under Form EIA-411 (all) 6,000 4,000 2,000 0 1960 1965 1970 1975 1980 1985 1990 1995 2000 Line Miles 2005 2010 2015 (2,000) [1]: Circuit miles of overhead electric lines from EEI's Historical Statistical Yearbook. Data excludes REA cooperatives. [2]: Courtesy of the North American Electric Reliability Corporation. NERC data is only available for lines 200kV and above. Note: transmission line additions are calculated as the difference in existing tranmission between the current and prior year (i.e. 2003 additions = 2003 miles - 2002 miles). [3]: Ventyx Suite. 1

Cost Allocation: A Barrier for Regional Projects Single-state projects Planning, permitting, and cost allocation process is easier (and more sequential): Planning determines need (e.g., overall benefits in excess of total project costs) State permitting process confirms need and approves project Approved projects receive cost recovery from customers within state Still, some challenges for in-state projects with regional benefits Multi-TO, Multi-State Projects Interaction between cost allocation and permitting creates barrier: Permitting often focused on costs and benefits to individual states and utilities: share of benefit in excess of allocated share of costs Beneficiary pays framework creates incentives to dismiss difficult-to-quantify benefits to achieve lower cost allocations Result: projects beneficial to region often do not appear beneficial to individual states or utilities based on their shares of costs and benefits 2

Challenge: Wide-spread Benefits Wide-spread nature of transmission benefits creates both planning and cost allocation challenges Broad in scope Wide-spread geographically Diverse in their effects on market participants Occur and change over long periods of time Increased reliability and operational flexibility Reduced congestion, dispatch costs, and losses Lower capacity needs and generation costs Increased competition and market liquidity Renewables integration and environmental benefits Insurance and risk mitigation benefits Fuel diversification and fuel market benefits Economic development from G&T investments Multiple transmissions service areas Multiple states or regions Customers, generators, transmission owners in regulated and/or deregulated markets Individual market participants may capture one set of benefits but not others Several decades Changing with system conditions and future generation and transmission additions Individual market participants may capture different types of benefits at different times 3

Benefits of Projects vs. Regional Plans Estimation of benefits frequently unworkable (or not even meaningful) on a project-by-project basis Sum of benefits of individual projects can be significantly less than the overall benefits of a comprehensive regional plan resulting in rejection of desirable projects Benefits distributed more uniformly for regional plans (complete portfolio of projects), facilitating cost allocation More uniform benefit distribution will make it easier to find allocation that is roughly commensurate with estimated benefits Portfolio of projects in regional plans allows consideration different types of benefits to different types of stakeholders makes it easier to achieve multi-state agreements 4

Interregional Cost Allocation Interregional cost allocation effort by Regional State Committee of Southwest Power Pool Pfeifenberger and Hou, "Seams Cost Allocation: A Flexible Framework to Support Interregional Transmission Planning, April 2012 Framework identifies best practices for interregional planning and cost allocation agreements, including: 1. Process to propose and analyze interregional projects 2. Benefits considered by each of the neighboring regions Avoid least-common denominator outcomes Each region should, at a minimum, consider all benefit metrics that are used for internal project evaluation Additional benefits provided by interregional transmission 3. Principles to determine cost sharing based on monetized benefits, contribution to needs, or rights to added capability 4. Payment mechanisms and transmission rights 5

Overreliance on Production Costs Savings Majority of economic planning processes measure only short-term dispatch cost savings without an evaluation of long-term resource cost impacts. For example, they: Over-rely on production costs and LMP impacts from dispatch simulation models which measure only fuel, variable O&M, and emission costs Ignores investment and fixed O&M cost of generation Evaluate a snap shot of the system without considering market response (e.g., reduction in market prices will tend to speed up retirements and delay new generation investments) Often assume same amount of generation is built (e.g., wind) and retained in same locations irrespective of the transmission investment 6

Often Overlooked Other Transmission Benefits Important transmission benefits are often overlooked because of production cost model limitations and the complexity involved in quantifying these benefits: 1. Enhanced market competitiveness 2. Enhanced market liquidity 3. Economic value of reliability benefits 4. Added operational and A/S benefits 5. Insurance and risk mitigation benefits 6. Capacity benefits 7. Long-term resource cost advantage 8. Synergies with other transmission projects 9. Impacts on fuel markets 10.Environmental and renewable access benefits 11.Economic benefits from construction and taxes These benefits can double benefits quantified in typical production cost studies 7 Additional market benefits Reliability/operational benefits Investment and resource cost benefits External benefits

Example: Electricity Market Benefits vs. Costs Total electricity market benefits of SCE s DPV2 project in CAISO exceeded project costs by more than 50% Expected Annual Benefits of DPV2 ($ millions) 125 100 75 50 25 0 56 Production Cost Benefits (Net of FTRs) 28 Competitiveness Benefits 20 Operational Benefits (RMR, MLCC) 8 12 Levelized Cost: 71 Source: Economic Evaluation of the Palo Verde-Devers Line No. 2 (PVD2), CAISO, February 24, 2005. Generation Investment Cost Savings 2 1 119 Reduced Losses Emissions Benefit Total Annual

Example: Electricity Market Benefits vs. Costs ATC s Paddock-Rockdale study: Significant net benefits (production cost savings alone exceeded costs in some scenarios) NPV of Expected Benefits Under High Environmental Scenario ($ Million) 250 200 150 100 50 0 80 Production Cost Benefits NPV Cost: 137 42 6 Source: American Transmission Company, Planning Analysis of the Paddock-Rockdale Project, April 2007. Loss Benefits incl. Refunds FTR and Congestion Benefits 9 49 Competitiveness Benefits (for limited WI Market-Based Pricing) 28 Note: adjustment for FTR and congestion benefits was negative in 3 out of 7 scenarios (e.g. a negative $117m offset to $379m in production cost savings) Insurance Benefit During System Failure Events 15 Capacity Savings From Reduced Losses 220 Total Benefits

RTOs Increasingly Address these Other Benefits SPP ITP analysis: Quantified 1. production cost savings 2. reduced transmission losses 3. wind revenue impacts 4. natural gas market benefits 5. reliability benefits 6. economic stimulus benefits of transmission and wind generation construction Not quantified 7. enabling future markets 8. storm hardening 9. improving operating practices/maintenance schedules 10.lowering reliability margins 11.improving dynamic performance and grid stability during extreme events 12.societal economic benefits (SPP Priority Projects Phase II Final Report, SPP Board Approved April 27, 2010; see also SPP Metrics Task Force, Benefits for the 2013 Regional Cost Allocation Review, July, 5 2012.) MISO MVP analysis: Quantified 1. production cost savings 2. reduced operating reserves 3. reduced planning reserves 4. reduced transmission losses 5. reduced renewable generation investment costs 6. reduced future transmission investment costs Not quantified 7. enhanced generation policy flexibility 8. increased system robustness 9. decreased natural gas price risk 10.decreased CO 2 emissions output 11.decreased wind generation volatility 12.increased local investment and job creation (Proposed Multi Value Project Portfolio, Technical Study Task Force and Business Case Workshop August 22, 2011) 10 CAISO TEAM analysis (DPV2 example) Quantified 1. production cost savings and reduced energy prices from both a societal and customer perspective 2. mitigation of market power 3. insurance value for high-impact low-probability events 4. capacity benefits due to reduced generation investment costs 5. operational benefits (RMR) 6. reduced transmission losses 7. emissions benefit Not quantified 8. facilitation of the retirement of aging power plants 9. encouraging fuel diversity 10.improved reserve sharing 11.increased voltage support (CPUC Decision 07-01-040, January 25, 2007 (Opinion Granting a Certificate of Public Convenience and Necessity)

Additional Reading Johannes P. Pfeifenberger and Delphine Hou, "Seams Cost Allocation: A Flexible Framework to Support Interregional Transmission Planning, April 2012. Pfeifenberger, Hou, Transmission s True Value: Adding up the Benefits of Infrastructure Investments, Public Utilities Fortnightly, February 2012. Pfeifenberger, Hou, Employment and Economic Benefits of Transmission Infrastructure Investment in the U.S. and Canada, on behalf of WIRES, May 2011. Pfeifenberger, Easier Said Than Done: The Continuing Saga of Transmission Cost Allocation, Harvard Electricity Policy Group meeting, Los Angeles, February 24, 2011. Pfeifenberger, Newell, Direct testimony on behalf of The AWC Companies re: the Public Policy, Reliability, Congestion Relief, and Economic Benefits of the Atlantic Wind Connection Project, filed December 20, 2010 in FERC Docket No. EL11-13. Pfeifenberger, Transmission Investments and Cost Allocation: What are the Options? ELCON Fall Workshop, October 26, 2010. Pfeifenberger, Transmission Planning: Economic vs. Reliability Projects, EUCI Conference, Chicago, October 13, 2010. Fox-Penner, Pfeifenberger, Hou, For Grid Expansion, Think Subregionally, The Energy Daily, June 8, 2010. Pfeifenberger, Chang, Hou, Madjarov, Job and Economic Benefits of Transmission and Wind Generation Investments in the SPP Region, The Brattle Group, Inc., March 2010. Comments of Peter Fox-Penner, Johannes Pfeifenberger, and Delphine Hou, in response to FERC s Notice of Request for Comments on Transmission Planning and Cost Allocation (Docket AD09-8). Pfeifenberger, Fox-Penner, Hou, "Transmission Investment Needs and Cost Allocation: New Challenges and Models," The Brattle Group, Inc., presented to FERC Staff, Washington, DC, December 1, 2009. Fox-Penner, Pfeifenberger, The Anchor-Tenant Model And Some of the Chickens and Eggs, The Electricity Journal Guest Editorial, Volume 22, Issue 6, July 2009. Pfeifenberger, "Assessing the Benefits of Transmission Investments," presented at the Working Group for Investment in Reliable and Economic Electric Systems (WIRES) meeting, Washington, DC, February 14, 2008. Pfeifenberger, Direct Testimony on behalf of American Transmission Company re: Transmission Cost-Benefit Analysis Before the Public Service Commission of Wisconsin, Docket 137-CE-149, January 17, 2008. Pfeifenberger, Testimony on behalf of Southern California Edison Company re: economic impacts of the proposed Devers-Palo Verde No. 2 transmission line, before the Arizona Power Plant and Transmission Line Siting Committee, Docket No. L- 00000A-06-0295-00130, Case No. 130, September and October, 2006. 11

About The Brattle Group The Brattle Group provides consulting and expert testimony in economics, finance, and regulation to corporations, law firms, and governmental agencies around the world. We combine in-depth industry experience, rigorous analyses, and principled techniques to help clients answer complex economic and financial questions in litigation and regulation, develop strategies for changing markets, and make critical business decisions. Our services to the electric power industry and users include: Climate Change Policy and Planning Cost of Capital and Regulatory Finance Demand Forecasting and Weather Normalization Demand Response and Energy Efficiency Electricity Market Modeling Energy Asset Valuation Energy Contract Litigation Environmental Compliance Fuel and Power Procurement Incentive Regulation 12 Market Design and Competitive Analysis Mergers and Acquisitions Rate Design, Cost Allocation, and Rate Structure Regulatory Strategy and Litigation Support Renewables Resource Planning Retail Access and Restructuring Strategic Planning Transmission Valuation and Risk Management

Speaker Bio and Contact Information Insert corporate headshot here. Johannes P. Pfeifenberger Principal, Utility Practice Area Leader Cambridge Hannes.Pfeifenberger@brattle.com 617.864.7900 office 617.234.5624 direct Note: The views expressed in this presentation are strictly those of the presenter and do not necessarily state or reflect the views of The Brattle Group, Inc. Johannes (Hannes) Pfeifenberger is an economist with a background in power engineering and over 20 years of experience in the areas of public utility economics and finance. He has published widely, assisted clients and stakeholder groups in the formulation of business and regulatory strategy, and submitted expert testimony to the U.S. Congress, courts, state and federal regulatory agencies, and in arbitration proceedings. Hannes has extensive experience in the economic analyses of electricity wholesale markets and transmission systems. His recent experience includes reviews of RTO capacity market and resource adequacy designs, testimony in contract disputes, and the analysis of transmission benefits, cost allocation, and rate design. He has performed market assessments, market design reviews, asset valuations, and cost-benefit studies for investor-owned utilities, independent system operators, transmission companies, regulatory agencies, public power companies, and generators across North America. Hannes received an M.A. in Economics and Finance from Brandeis University and an M.S. in Power Engineering and Energy Economics from the University of Technology in Vienna, Austria. 13