Uniform Price vs. Differentiated Payment Auctions

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Uniform Price vs. Differentiated Payment Auctions A Discussion of Advantages and Disadvantages PREPARED FOR Independent Electricity System Operator ICA Fundamentals and Concepts Stakeholder Meeting PREPARED BY Johannes P. Pfeifenberger Roger Lueken Kathleen Spees Lily Mwalenga June 15, 2017 Copyright 2017 The Brattle Group, Inc.

Agenda Overview Uniform Price Auctions Pay-as-Bid Auctions Differentiated Payments for Existing and New Resources Implications for Ontario 1 brattle.com

Overview Some stakeholders have posed the question of whether all resources should be paid the same price in the capacity auction or whether different prices should be paid to different resources To help inform that question, we look at the theoretical and practical implications for Ontario with: Uniform Price Auctions: All resources paid the same price Pay-as-Bid Auctions: Cleared resources paid at their offer price New vs. Existing: Differentiated payments for new and existing resources We review the advantages, disadvantages, and implications for Ontario for each of these approaches and provide our thoughts 2 brattle.com

Agenda Overview Uniform Price Auctions Pay-as-Bid Auctions Differentiated Payments for Existing and New Resources Implications for Ontario 3 brattle.com

Uniform Price Auctions How Uniform Price Capacity Auctions Work Sellers submit offers to sell capacity and lowest-price offers are selected Highest selected offer sets uniform clearing price paid to all resources Price Uniform Price Auction Clearing Clearing Price Suppliers offer capacity at price taker bids or net going-forward costs All suppliers earn price set at the marginal system cost Same Approach Used in: Ontario s energy market Other capacity markets (PJM, NYISO, ISO-NE, MISO) Cleared Quantity Quantity 4 brattle.com

Uniform Price Auctions Advantages Uniform price auctions achieve the most efficient results in the short run and in the long run Incentives for Suppliers: Most significant advantage is that it incentivizes suppliers to offer at the lowest-acceptable price to maximize their likelihood of clearing profitably. Other advantages are mostly a consequence of this incentive Societal Costs: Minimized, as market clears the lowest-cost mix of resources* Customer Costs: Minimized in the long run, as long-run customer costs are lowest when societal costs are minimized Equity: Recognizes equal value for all providers of the same product (MW of capacity, derated for probability of being available to serve load) Innovation: Competition across all resources creates strong incentives for innovative, low-cost resources to enter Mitigation: allows for enhanced market power monitoring and mitigation Tested: Proven, well-functioning approach used in all capacity markets to date * Customer costs = price x cleared quantity. Societal costs = producers investment + production costs. 5 brattle.com

Uniform Price Auctions Disadvantages Primary Disadvantage: Hockey-stick shaped supply curve can create price volatility. It accurately reflects underlying economics, but produces challenges: Year-to-year price swings may be large Exposure to exercise of market power if not mitigated Challenges can be managed via market design Price volatility limited by sloped demand curve and forward auctions Robust market monitoring and mitigation to limit exercise of market power With performance incentives (new PJM or ISO-NE approach), supply curve is flatter Example Supply Curves from PJM Sources and Notes: http://www.brattle.com/system/testimonies/pdfs/000/001/026/original/tes timony_of_newell Spees_and_Oates_Docket_No._ER17-284- 000.pdf?1478644510 6 brattle.com

Agenda Overview Uniform Price Auctions Pay-as-Bid Auctions Differentiated Payments for Existing and New Resources Implications for Ontario 7 brattle.com

Pay-as-Bid Auctions How Pay-as-Bid Auctions Work Sellers are incentivized to offer above cost (and just below the highest expected clearing price) to clear at a high market price Cleared offers are paid at their offer price Price Pay-as-Bid Auction Clearing True Supplier Costs Suppliers offer capacity with bids slightly below the anticipated clearing price All suppliers paid at asset-specific offer price Cleared Quantity Quantity 8 brattle.com

Pay-as-Bid Auctions Customer Costs in a Pay-as-Bid Auction Common misperception is that customer costs would be lower with pay-asbid auction compared to uniform price In reality, customer costs are likely to be similar or higher because supplier bids are incentivized to be higher Price Misperception: Suppliers Offer at Cost Price Reality: Suppliers Offer at Expected Clearing Price Supplier offers at true cost Clearing Price in Uniform Price Auction Perceived Customer Savings Perceived Customer Costs Actual Customer Costs Suppliers offer at higher prices above cost Clearing prices may rise Customer Costs in Excess of Uniform Price Auction Cleared Quantity Quantity Cleared Quantity Quantity 9 brattle.com

Pay-as-Bid Auctions Advantages of Pay-as-Bid Auctions Primary advantages are associated with the relatively flatter supply curve in pay-as-bid auctions Volatility: Decreases price volatility and customer cost volatility to the extent participants accurately anticipate clearing prices (does not reduce supplier revenue volatility due to risk of not clearing) Market Power: Can reduce incentives and ability to exercise market power (as long as there is a sufficient number of suppliers and they have limited information about others offers and final clearing results) 10 brattle.com

Pay-as-Bid Auctions Disadvantages Auction format incentivizes offers above net going-forward cost, potentially leading to undesirable outcomes Inefficient Clearing: Low-cost resources may offer too high and fail to clear, causing them to exit while higher-cost resources enter Higher New Entry Offer Prices: New entrants will need to offer at higher prices due to risk of not clearing in subsequent auctions, creating a target price above that of a uniform price auction* Disadvantages Small and New Suppliers: Creates an economic advantage for incumbents and large players with more information about supply offers Higher System and Customer Costs: Inefficiencies will tend to drive higher system and customer costs than uniform price auction Example of Inefficiency: Supply Offers Not Reflective of True Cost Resulting in Inefficient Resource Selection Price High-Cost Supply Clears the Auction Low-Cost Supply Offers Slightly Too High & Fails to Clear *As illustrated in the figure, low-cost resources face the risk of not clearing the auction if they inadvertently offer above the highest accepted offer price. Supply Offers Quantity True Supplier Costs 11 brattle.com

Agenda Overview Uniform Price Auctions Pay-as-Bid Auctions Differentiated Payments for Existing and New Resources Implications for Ontario 12 brattle.com

New vs. Existing Perspectives: Differentiating New/Existing Supply Perspectives of customer and existing supplier likely differ significantly on whether it would be appropriate to differentiate payments to new and existing resources Potential Customer Perspective Existing suppliers have already earned back investment costs under prior contracts Existing resources do not need the same capacity revenue as new resources to keep operating Customer costs will be lower if existing resources are paid less Unfair to ask customers to pay above cost for previously-contracted resources Potential Supplier Perspective Suppliers participating in RFPs for new contracts assumed some terminal value (investment costs not fully recovered) Existing plants need capital expenditures for reinvestment/refurbishment to continue operating and compete with new plants Taking on new risk of low or volatile capacity prices (as observed in other markets) Unfair to pay less when providing the same value 13 brattle.com

New vs. Existing Perspectives Driven by Worst Case Scenario Customers are likely to focus on the risk of high prices. Suppliers will focus on the risk of low prices Customers Concern Previously-Contracted Resources Earn Revenues Above Going-Forward Costs Suppliers Concern Capacity Prices May Be Low (As Realized in Other Capacity Markets) Price Clearing Price New Resources Price New Resources Large Net Revenues to Previously Contracted Resources Existing Resources Quantity Perceived high-cost scenario: New entry required at a high cost; low going-forward costs for previously-contracted resources Result: Customers may see high revenues to previously-contracted resources as unfair if they have already recovered investment costs Clearing Price Existing Resources Small Net Revenues to Previously Contracted Resources Quantity Realized scenario in other capacity markets: Innovation, competition, and low-cost entry keep customer costs low Result: Customers benefit from low costs (existing suppliers may earn insufficient revenue to continue operating) Existing Resources Retire Due to Low Capacity Prices 14 brattle.com

New vs. Existing Advantages of Differentiated Payments Primary advantage of differentiated payments is the possibility to contain customer costs over a transitional period (not an advantage from a supplier or efficiency perspective) Short-Run Customer Cost Savings: Customer costs may be lower in the short run with differentiated payments under certain specialized conditions as long as: Capacity prices clear at high levels, significantly above most existing resources costs Existing resources would not retire even at lower payments (e.g. assuming that there are minimal fixed or reinvestment costs required to stay online) Impacts of differentiation (inefficiencies and reduced competition between existing and new resources) are modest No Customer Savings Longer-Term: Over time, customer benefits will erode and possibly reverse due to growing inefficiencies (see next slide) 15 brattle.com

New vs. Existing Disadvantages Primary disadvantage of differentiating payments is the economic inefficiency that would be introduced Higher-Cost Supply Mix: Preferential treatment for new resources will introduce greater incentives to attract higher-cost new supply, even while lower-cost existing resources may retire prematurely (less competition between existing and new resources) Higher Prices Needed to Attract Entry: New entrants will wait for higher prices before entering the market due to prospects of low revenue once they become existing supply Higher Long-Run Customer Costs: Customer costs may be lower during a transition period, but will eventually rise higher than in a resource-neutral approach due to the impact of economic inefficiencies and reduced competition Equity and Implementation Challenges: How to define new vs. existing capacity? What price to pay existing resources? How long to set the transitional period? 16 brattle.com

New vs. Existing California Experience with Differentiated Payments California has separate mechanisms for compensating new and existing supply New Capacity: Competitively-procured under 10-year contracts based on regulatory planning Existing Resources: Procured via shortterm bilateral capacity market Differentiation led to inefficiencies and higher customer costs: New plant contracts significantly above Net CONE (due to need to earn full capital costs over 10-year contract) More new capacity procured than needed for supply adequacy (due to difference in timing of procurements) Relatively-new existing plants retire after contract expiration (e.g. Sutter plant) California: New vs. Existing Capacity Payments Existing Plant Capacity Prices New Plant Contract Prices Estimated Net Cost of New Entry Source: http://www.brattle.com/system/publications/pdfs/000/004/827/ori ginal/resource_adequacy_in_california_calpine_pfeifenberger_s pees_newell_oct_2012.pdf?1378772133 17 brattle.com

Agenda Overview Uniform Price Auctions Pay-as-Bid Auctions Differentiated Payments for Existing and New Resources Implications for Ontario 18 brattle.com

Implications for Ontario Uniform Price Auction: Evolving as best-practice approach based on international experience. Expected to achieve lowest societal costs and lowest customer costs in long-run Pay-as-Bid Auction: Would likely lead to inefficiencies, customer cost implications, and other challenges. Moderately higher price stability are not commensurate with significant risks and disadvantages New vs. Existing: Need to evaluate whether, despite the phase-in under the incremental auction design, the risk of high-priced outcomes during phase-in is anticipated to be materially greater than the risk of inefficiencies that may be introduced through differentiated pricing. If pursuing this option, consider limiting application only to guard against high-price outcomes, only to previously-contracted resources, and only over a limited transition period 19 brattle.com

Biography and Contact Information JOHANNES P. PFEIFENBERGER Principal Cambridge Hannes.Pfeifenberger@brattle.com +1.617.864.7900 Mr. Pfeifenberger is an economist with a background in electrical engineering and over twenty-five years of experience in the areas of electricity markets, regulation, and finance. He has assisted clients in the formulation of business and regulatory strategy, submitted expert testimony to the U.S. Congress, courts, arbitration panels, and regulatory agencies around the world, and provided support in mediation, arbitration, settlement, and stakeholder processes. Mr. Pfeifenberger specializes in electricity market design, utility industry regulation, transmission cost-benefit analyses and network access, financial valuation, energy industry litigation, and business strategy. On behalf of his clients, Mr. Pfeifenberger has addressed resource adequacy and capacity market designs, the economic benefits and cost allocation of transmission projects, the reasons behind rate increases, implications of restructuring policies, competitive conduct in electric power markets, and the effects of proposed mergers. He has also explored the benefits of alternative regulation, the desirability of settlement proposals, and the impact of regulatory and legislative actions in the context of evolving market conditions. Mr. Pfeifenberger 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. The views expressed in this presentation are strictly those of the presenter(s) and do not necessarily state or reflect the views of The Brattle Group, Inc. 20 brattle.com

Biography and Contact Information ROGER LUEKEN Associate Washington, DC Roger.Lueken@brattle.com +1.202.419.3321 Dr. Lueken is an economist and engineer with expertise in wholesale electricity market design, environmental policy design, asset valuation, and business strategy. Dr. Lueken has worked with clients throughout the U.S. and internationally, including market operators, regulated utilities, and market participants. Electricity market design assignments include designing and implementing capacity markets; enhancing energy and ancillary service market scarcity pricing; incorporating climate policies into market design; evaluating market reforms to support the high levels of renewable generation; and identifying system resource adequacy requirements in the face of uncertainty. He has supported utilities and merchant investors with multiple asset valuation studies of generation and storage assets in CAISO, ERCOT, and PJM. Dr. Lueken earned his Ph.D. in Engineering and Public Policy from the Carnegie Mellon Electricity Industry Center at Carnegie Mellon University, and a Masters of Engineering and Public Policy from the University of Maryland. The views expressed in this presentation are strictly those of the presenter(s) and do not necessarily state or reflect the views of The Brattle Group, Inc. 21 brattle.com

About The Brattle Group The Brattle Group provides consulting and expert testimony in economics, finance, and regulation to corporations, law firms, and governmental agencies worldwide. We combine in-depth industry experience and rigorous analyses 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 include: Climate Change Policy and Planning Rate Design and Cost Allocation Cost of Capital Regulatory Strategy and Litigation Support Demand Forecasting Methodology Renewables Demand Response and Energy Efficiency Resource Planning Electricity Market Modeling Retail Access and Restructuring Energy Asset Valuation Risk Management Energy Contract Litigation Market-Based Rates Environmental Compliance Market Design and Competitive Analysis Fuel and Power Procurement Mergers and Acquisitions Incentive Regulation Transmission 22 brattle.com

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