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Reliability and Economics: Separate Realities? James F. Wilson Principal, Wilson Energy Economics Harvard Electricity Policy Group Sixty-Fifth Plenary Session Dallas, Texas December 1-2, 2011 1

Reliability Three Broad Categories 1. Transmission system 2. Distribution system 3. Resource adequacy (generation, transmission, demand response) Our focus today: #3, resource adequacy 2

Panel Q: Should We Inject Economics Into Reliability? 1. Transmission system operation reliability/cost tradeoffs? 2. Distribution system we already do (tree trimming, etc.) 3. Resource adequacy we inject reliability into economics 3

Resource Adequacy Planning Over/Under Study (1978) Source: Decision Focus, Inc. Costs and Benefits of Over/Under Capacity in Electric Power System Planning, EPRI Report EA-927, Oct. 1978 Insights from Over/Under study: Flat curve: Cost is minimized over a wide range of PRMs Asymmetry: Under capacity risk greater than Over risk Important drivers of PRM: Demand growth, uncertainty (big) New plant lead times (long) Planning flexibility (valuable) Value of Lost Load (same as today) 4

Common Industry Practice: One Day in Ten Years 1-in-10 is a very conservative criterion that does not balance the marginal cost of the last incremental of capacity against its benefit (primarily, avoiding outages) 1-in-10 provides roughly two orders of magnitude more delivered reliability than provided by distributions systems In addition, approaches to calculating 1-in-10 PRMs generally make very conservative assumptions (so its not really 1-in-10) Highly conservative PRMs make more sense for utility planners and regulators than for consumers Wilson, James F., Reconsidering Resource Adequacy Part 1: Has the one-day-inten-years criterion outlived its usefulness? Public Utilities Fortnightly, April 2010. 5

Resource Adequacy Over/Under: Then, Now and Future Load growth Incremental capacity Then Now Future 2% to 7%/year, highly uncertain Large nuclear, coal, natural gas 1.2%/year, much narrower range Uprates, extensions, gas, DR, renewables Still falling? Increasingly diverse Lead times >> 3 years Most <= 3 years Various Over risk Under risk Small load growth quickly absorbs excess capacity Large inelastic, rapidly growing demand, long lead times to catch up Larger load growth slow, capacity may be excess for years Smaller peak grows slower and is more manageable, many short lead time resources Larger load growth uncertain Demand increasing price-responsive; better shortage pricing to activate 6

Peak Load Growth Is Slowing Source: NERC Long Term Reliability Assessment 2011 7

Short Lead Time, Low Investment Resources: 82% of PJM Incremental Capacity Over 8 Delivery Years Net increase in capacity imports 21% New CT/GT 5% New combined cycle 7% All other new generation 6% Generation upgrades 12% Demand response and energy efficiency 39% Withdrawn or cancelled retirements and reactivations 10% Source: PJM, 2014/2015 RPM Base Residual Auction Results, Tables 7 and 9, which present offered capacity expressed in installed capacity terms. 8

Injecting Reliability Into Economics: PRMS in Competitive Wholesale Power Markets Why are administrative PRMs imposed on some restructured, competitive wholesale markets? Sanctity of the one day in ten years criterion Concern that market participants may not act to provide enough total capacity Is adequacy a common good? Inadequate ncentives for merchant capacity construction under current wholesale market rules with limited demand elasticity 9

Over/Under Revisited: Wholesale Markets Total Cost Outage cost Variable cost region of lowest cost Fixed or capacity cost Market participants (buyers and sellers) make their own decisions to contract or build capacity, or hedge energy, ancillary services and capacity costs, based on their private assessments of load growth, capacity needs, prices, etc However, in aggregate, the relationship between total market cost and the actual reserve capacity may be similar to the regulated utility case. Total Market Reserve Margin 10

PRM in a Restructured Power Market: Total Market Cost Total Cost region of lowest cost PRM is non-binding Planning Reserve Margin With a relatively low PRM, market participants (buyers and sellers) cause more capacity to be built than the PRM; it is a nonbinding constraint and has no effect. To realize a larger PRM, a mechanism is needed to override the aggregate result of market participants assessments of capacity needs and capacity and hedging decisions (carrots or sticks) 11

RTO Actions and Interventions for Resource Adequacy Most proactive/ greatest intervention Years forward mandatory residual auction to achieve PRM (PJM, NE) Near-DY mandatory residual auction to achieve PRM (NY) Voluntary mechanisms to assist LSEs (MISO) DY obligations for LSEs w/enforcement Information only PRM study and report 12

Cost to Consumers With Mandatory Forward Capacity Obligations Total Cost to Consumers region of lowest cost Capacity cost reflecting mandatory auction with steep capacity "supply curve" (based on PJM assuming 50% hedging) Higher PRMs, through a mandatory auction, can cause large transfers of wealth from consumers to capacity sellers Supply curves for incremental capacity are very steep and do not include all capacity that can be available for the delivery year The transfers of wealth are hoped to incent future capacity construction, however, the evidence to date is not supportive. Planning Reserve Margin 13

Capacity Auction Supply Curves Remain Steep (PJM example) Source: The Brattle Group, Second Performance Assessment of PJM s Reliability Pricing Model, August 2011 14

The Impact of an Administrative Years-Forward PRM on Actual Delivery Year Capacity, Total Cost Is Complex (PJM Example) 3 years forward 2 years forward 1 year forward months forward Delivery Year Market participants actions to contract, sponsor new, retire capacity RTO Load forecast, PRM Updated forecast, PRM Updated forecast, PRM Updated forecast, PRM Actual load Mandatory auction Adjustment auction Adjustment auction Adjustment auction Delivery Year Capacity $$ for most capacity $ $ $ DY Total Cost 15

Transmission Planning Bright Line Tests Also Ignore Economics (PJM Example) 0.00 0.04 Transmission Capacity and LOLE PJM Mid Atlantic Region, 2009 analysis of 2014 0.10 0.20 Achieving "One Day in 25 Years" (LOLE= 0.04) requires 4600 MW of import capacity LOLE 0.30 PJM's Bright Line Test for Transmission Need Is Based Upon "One Day in 25 Years" for Regional Constraints 0.40 0.50 0.60 0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000 Mid Atlantic Region Transmission Import Capacity (MW) 16

Conclusions: Resource adequacy under 1-in-10 1. One Day in Ten Years ignores economics, is too conservative a. Fails to balance cost of capacity and probability, cost of outages; and conservative assumptions often used in determining 1-in-10 PRMs b. Capacity Over/Under risks have changed significantly in recent years, (slower load growth, short-lead-time resources, more manageable peaks) c. With substantial PRD, modeling 1-in-10 becomes arbitrary, meaningless 2. Traditional, conservative PRMs based on 1-in-10 harm consumers and markets a. Pre-empts market decision-making, stunting market development b. The resulting excess capacity depresses E&AS prices and discourages DR and PRD, which hold the potential to make markets more efficient c. Large PRMs can result in large transfers of wealth from consumers to capacity sellers without commensurate short-term or long-term benefit d. Forward capacity markets become entrenched and create a constituency in favor of conservative PRMs that raise capacity prices 17

Conclusions: Economic evaluation of PRMs 3. Modeling the economic impacts of resource adequacy criteria and resulting PRMs in a market context is complex and the results will necessarily depend on many questionable model structure choices and assumptions a. Connection between administrative PRM and delivery year actual RM b. Connection between actual RM and energy, A/S, capacity prices c. Connection between all prices and market participants future capacity decisions (multi-year dynamics) d. Theory v. actual impact of forward capacity markets 4. The structure and focus of the Over/Under approach is not well suited for modeling the dynamics of power markets 5. Communicating probabilistic resource adequacy analyses is also challenging ; simplified presentation can provide a highly inaccurate impressions of risks (example: transmission bright line test) 18

Conclusions: Resource adequacy for restructured markets 6. For restructured markets under RTOs, PRMs are a market intervention that should remain focused on resource adequacy a. Purpose: To protect against unacceptably low RM leading to unacceptable risk of frequent curtailment of firm load (guard rails) b. Not to optimize the economics not appropriate in a market context c. Not to try to send price signals evidence (and theory) do not support effectiveness of spot capacity market prices in incenting new capacity 7. The goal should be to phase out administrative PRMs (or see them become non-binding) through further development of demand-side price responsiveness and better pricing when reserves are low 8. Attitudes that reliability is paramount applied to resource adequacy (as opposed to grid operation) are outdated and must change with the times 19

Related Work (available at www.wilsonenec.com) Wilson, James F., Reconsidering Resource Adequacy, Part 1: Has the one-day-in-10-years criterion outlived its usefulness? Public Utilities Fortnightly, April 2010 Link Wilson, James F., Reconsidering Resource Adequacy, Part 2: Capacity planning for the smart grid, Public Utilities Fortnightly, May 2010 Link Wilson, James F., One Day in Ten Years? Resource Adequacy for the Smart Grid, revised draft, November 2009 Link Wilson, James F., Comments on Proposed Reliability Standard BAL-502-RFC-02: Planning Resource Adequacy Analysis, Assessment And Documentation, FERC Docket No. RM10-10, Dec. 27, 2010 Link Wilson, James F., Forward Capacity Market CONEfusion, Electricity Journal, November, 2010 Link Wilson, James F., Direct Testimony on Behalf of Virginia State Corporation Commission Staff, Application of PATH Allegheny Virginia Transmission, Virginia State Corporation Commission Case No. PUE-2009-00043, December 8, 2009 Link Wilson, James F., Affidavit in Support of Comments and Protest of the Pennsylvania Public Utility Commission, FERC Docket No. ER09-1063-004 (shortage pricing), July 30, 2010 Link 20