Edison Electric Institute

Suppose the experts are wrong about climate change. Suppose they’ve underestimated the impact of global warming. Of course, to longtime readers of Public Utilities Fortnightly, the idea that a warming climate might force adjustments in utility resource plans is nothing new.

The heavy investment required for new generation technologies clearly is a global phenomenon, but global-resource competition to build power plants is making power-plant development more expensive—and may even limit the number that any one utility in any one country can develop.

For a front-line perspective on FERC’s policy direction, we asked one of the industry’s most prominent policy representatives, David K. Owens at the Edison Electric Institute, to provide his take on FERC’s competition conference and Order 890.

After pleading with Congress for so many years, and then at last winning the requisite legislative authority to impose mandatory and enforceable standards for electric reliability, to replace its legacy system of voluntary compliance, NERC finds itself at a curious juncture. It wants to slow the transition.

Hold on to your hats. The vaunted and vilified “standard market design”, once thought dead and buried, has been resuscitated, with all attendant chaos and rhetoric, but this time in the guise of a new proposal under the code name “open dispatch.” This new construct, as remarkable in its way as Einstein’s theory of indeterminate space and time, declares that electric transmission, long seen as one of a triumvirate of unique and essential utility industry sectors (along with generation and distribution), is little more than a mirage.

FERC demonstrated strong leadership in meeting the aggressive timeline set by Congress for establishing the regulatory basis on which the Electric Reliability Organization will be created. But next summer’s peak-demand season is fast approaching. And much more work remains ahead for the industry to finish the job.

As the industry’s regulatory risks and capital requirements expand, financing will come with a higher price tag—and another cost pressure in the ratemaking process.

How will utilities in the next 10 years manage a multi-billion-dollar infrastructure buildout, higher interest rates/cost of capital, diminishing free cash flows, state renewable mandates, and political pressures to keep rates or power prices low, all while complying with carbon emissions programs that emphasize higher-cost fuels? Meeting the challenges may depend on whether a national carbon program that regulates carbon emissions is established.

By almost any measure, the nation is running short of transmission, and the existing volume of investment cannot long continue to reliably accommodate retail-load growth and larger wholesale volumes. Factors like environmental opposition also have caused declines and delays in transmission investment, but it seems clear that financial transmission rights and regulated returns have not sufficed to induce the necessary construction. The authors propose a new model to reward investors who lower congestion costs.

Some states, including Illinois, Oregon, Pennsylvania, and Texas, have been considering smart-metering questions as part of rate cases and resource-planning discussions. Other states, such as Kentucky, Louisiana, Ohio, and Virginia, have initiated EPACT Section 1252 inquiries separately from other proceedings. The tenor of the discussion also varies from state to state, with high-cost power states generally more attracted to AMI than low-cost states are.