|
||||||||||
The Presence of Market Failure. Current estimates put EE at around 3.5 cents per kWh equivalent. By contrast, the average current rate charged to consumers across the country is around 9.1 cents per kWh (EIA State Electricity Profiles, 2007 Edition). Assuming DSM programs mimic the overall EE cost profile and viewing DSM as a competing substitute product for fleet generation, the significant difference between these two numbers indicates the presence of market friction or market failure that has prevented changes over recent decades in investment ratios by IOUs between DSM and fleet generation. The cost differential also demonstrates an opportunity to save enormous amounts of money on energy going forward by simply incorporating more EE into our energy provisioning choices.
In a market without friction, EE demand would have expanded to offset new fleet generation until such time as EE cost advantages are eliminated. With EE costing less than half the current average kWh rates in the US, what has been the history of EE penetration within the market and what are the current sources of market friction that are preventing EE from achieving greater market penetration?
The Extent of Market Failure. The extent of market failure in the current market state is hard to estimate as the analysis requires assumptions on the level of EE demand versus fleet generation that would exist in the market today had the energy markets performed under ideal conditions over the last several decades. This analysis would require assumptions on how EE programs and kWh costs would have evolved differently under differing levels of demand growth.
The potential savings associated with more aggressive use of EE have been documented through reports like Unlocking Energy Efficiency in the U.S. Economy produced recently by McKinsey. McKinsey estimates that the US could generate a 23% savings in overall energy usage by the year 2020 over a business-as-usual trend through aggressive implementation of EE. This estimate includes cumulative present value savings in energy usage for both electricity and natural gas of $1.2 trillion through 2020.
As a comparative to the McKinsey study, a review of energy trends shows that a policy goal of satisfying all demand growth for kWh (limiting the analysis to the electricity market) between 2010 and 2020 would yield savings of 4.1 quad in fleet kWh demand with reduced kWh sales of $353 billion (area A in Chart 1). Assuming EE costs remain level at 3.5 cents per kWh equivalent, the $379 billion in reduced kWh sales are offset by $145 billion in EE expenditures for a net savings of $234 billion for the economy over this time period (ignoring profits built into current kWh rates).
An important complicating assumption is the rate at which increasing investments in EE would close the cost advantage that EE currently enjoys. As EE expenditures ramp up, investments will flow to more marginal EE programs up to the point where the value derived from EE would equate to the value provide by fleet generation. If EE costs increase to from 3.5 cents to 9.1 cents per kWh equivalent from 2010 to 2020, the cumulative economic benefits are reduced to $77 billion.
Assuming that EE costs per kWh equivalent more than double over a period of significant expansion in demand for EE is pessimistic as the increased demand will logically lead to innovations that expand EE utilization at reduced costs. This pessimistic scenario is offered to provide both upper and lower limits on expected savings from increased EE utilization. An interesting area of study going forward is the impact of escalating EE demand on underlying costs as EE expenditures ramp up.
Market Imperfections. What stands in the way of taking fuller advantage of EE? Simply put, if all customers and suppliers had full information and zero transaction costs for implementing all energy utility generating products -- including EE -- the market would move to equate the value derived for each product utilized (allocative efficiency). So why is this not happening?
There are many causes for market imperfection in the EE market and many of these causes receive excellent treatment in the McKinsey study. A primary market failure involves regulatory structures that do not allow IOUs to earn additional profits by introducing more EE in the market through DSM programs. This topic has also received considerable coverage over the years yet the number of states and programs that address this market failure are very few.
The McKinsey study breaks the barriers out into fundamental attributes of the EE market and into an "Opportunity-Specific" category, which is further broken into Availability, Behavioral, and Structural barriers. My focus here is on a single structural defect associated with the impact of recovering fixed costs through usage sensitive rates. Having quantified the impact of this challenge, how to address the concerns around fairness and efficiency that the industry must address before significant expansion in EE utility-based programs is possible must be addressed.
The Dilemma of Rate Increases. Implementing lower cost EE programs has the undesirable impact of increasing per-kWh rates for IOUs over the short run. The existing structure of both the electricity industry and the regulatory rules controlling pricing and cost recovery provide this curious result. The supporting pillars for this structural defect are as follows:
- Utilities have large fixed costs built into usage sensitive rates;
- The vast majority of state regulatory systems do not include straight fixed/variable pricing structures that break out fixed costs from usage sensitive kWh sales; and,
- Utilities' IRPs include significant margins to ensure peak demand is provided without interruption and include purchased power with very long contracts.
The EE investments only avoid the variable costs associated with the fleet generated kWh that are supplanted by EE. The financial math associated with this effect is that total expenditures to meet overall energy demand are increased over the short run even though the EE programs may actually costs less than half of current kWh rates when reviewed from an average total cost perspective.
A simple example is presented in Table 1. This table shows a utility that has 80% fixed costs and 20% variable costs associated with the sale of fleet generated kWh. This scenario assumes that the current rate per kWh is 9.1 cents per kWh and fuel input and other variable costs equate to 1.8 cents per kWh (20%). Introducing new DSM programs that reduce overall demand by 5% will serve to increase usage sensitive kWh rates by 4.2% under these conditions. The rate impact increases to 6.2% if none of the EE costs of 3.5 cents per kWh equivalent are paid by the EE beneficiaries but are instead added into rate base. This end result is provided solely to show the overall impact on costs, however, as participants in utility-based DSM programs typically pay a sizeable percentage of the total costs.
This scenario shows that total costs are increased for providing the combined total energy 'utility' expressed by kWh from fleet generations and kWh equivalents from EE. Even though EE costs less than 50% of total average fleet generation costs, it is the comparison of incremental costs for existing kWh capacity against total costs for new EE investments that becomes relevant for determining pricing impacts. The existing fixed and operational costs built into usage sensitive rates must be weaned out of the pricing structure through amortization over time or through fixed/variable pricing in order to reduce the impacts of the EE programs on usage sensitive rates.
EE programs drive down overall costs at the point where EE programs offset the need for new fleet generation capacity. At this critical juncture, the combined fixed and variable costs associated with the new fleet generation investments are compared equitabily against total EE costs. A current example from Florida provides a good perspective here. In a docket pertaining to additional DSM programs, one Florida utility showed an average increase in rates of 0.338% associated with an incremental DSM quantity of 1.3% of peak over a 9 year planning horizon (Florida docket 080407-EG). The rate increases are over and above the utility's current IRP plans which utilize existing capacity and purchased power to meet margin requirements over the next decade. It is only in year 10 of the program, when a planned addition to fleet generation is avoided, does the price calculation become favorable turning into a 0.271% decrease in rates. This example clearly shows the negative impact associated with incremental spending to produce energy (in this case energy avoidance through kWh equivalents) when compared to existing IOU long term capacity planning.
DSM Price Impact Elasticity. Estimates of DSM program impacts on rates can be generated by varying either the percentage of fixed versus variable costs built into rate structures or the level of demand aviodance relative to total. Using the simplified scenario outlined above and changing the levels of variable costs while holding demand avoidance at 5% produces Chart 2.
This analysis is based on the situation where existing demand is reduced through EE programs leading to an overall reduction in kWh sales. Situations where kWh growth is offset by EE programs will need to compare EE costs to proposed spending on incremental fleet generation capacity over the relevant time horizon. If no incremental fleet capacity is needed, the comparison will be between largely fuel cost-based incremental costs for fleet kWh and total EE program costs.
Perhaps a more interesting chart holds the percentage of incremental costs flat at 15% while changing the level of avoided demand. This relationship is depicted in Chart #3 and allows for a very rough estimate of rate impacts associated with the fixed cost penalty with varying amounts of demand avoidance.
This style of analysis should allow regulators to assess at a high level the size of fixed cost penalty rate payers will face given the percentage of avoidable costs and the level of DSM planned for implementation under conditions where no new fleet generation capacity is avoided.
How Big A Deal is the Fixed Cost Penalty? Offsetting all projected growth in kWh demand for the US economy using EE at 3.5 cents was discussed as a scenario above. The level of rate impact will be associated with both factors: 1) the fixed cost penalty; and, 2) the savings from using lower cost EE programs. Using data from the EIA and the simplified analysis in this paper, impacts on national rates associated with eliminating all demand growth through EE programs can be estimated. Impacts can be broken into three scenarios.
- Worst case scenario involves rate increases assuming all demand growth and costs are built into current IRPs such that the EE programs represent reduced demand against static fixed costs.
- Best case scenario generates price reductions from substituting EE at 3.5 cents per kWh for all new demand growth and assuming no negative fixed costs penalty.
- Most likely scenario where a portion of the negative fixed cost impacts on rates would be mitigated by avoided new plant construction costs.
The composite view (which is not Scenario 3), on the other hand, shows a rate per kWh equivalent as it prices into the mix the cost of kWh avoidance through EE programs. As such, the composite view is not providing an estimate of the per kWh rate that IOUs would be charging customers, but rather a proxy for the implicit rate customers will experience through combined kWh and EE purchases.
Scenario 3 involves assuming when the additional fleet generation investment becomes 'avoided' allowing for a reduction in the fixed cost penalty. This analysis would need to be done on an individual IOU basis. However, in looking at the total energy market in the US economy, it is logical that the rate of avoided investment would become 'smooth' due to the large numbers of utilities involved. Another interesting study would be to understand this effect better in order to predict the impacts of national EE policies that cross many utilities versus decisions impacting one IOU at a time.
Table 2 shows that rate impacts can vary between raising 15% or falling 10% with a composite view showing 5% price increases over 10 years. Considerations impacting the composite view are the pace of fleet generation avoidance and the impact of increasing demand in EE programs on the cost effectiveness for EE. Each of these dynamic impacts merit additional research.
People will have differing opinions on how impactful a 5% price increase over ten years will be on consumers. Given the increasing environmental costs within the energy industry going forward, this level of price increase appears to be modest.
Impacts on Consumers. Perhaps the most contentious aspect of the fixed cost problem is the differential impact on consumers associated with IOU DSM programs. Customers that take advantage of DSM programs generally see their overall energy bill reduced. Costs not recovered directly from DSM program customers get spread onto general rate base customer through either EE cost recovery charges or thorough the per kWh rate like the fixed cost induced rate increases discussed above. This asymmetric impact causes significant concerns with consumer groups based upon equity and fairness considerations.
In the case of DSM programs, a solution must be found where the consumers that benefit are able to offset the additional costs of consumers that are harmed. This is also an area that has received considerable attention over the last several decades through debates on the appropriate tests to use for approving DSM programs. Policy solutions that address these equity considerations while working to optimize EE investments appear to be few in number.
Conclusions. The energy industry indicates the presence of significant market failures by the modest growth in IOU-based DSM programs relative to the significant cost advantages of EE over additional fleet generation. Regulatory structures common within the industry provide an unexpected challenge of increasing usage sensitive rates over the short to medium run when additional DSM programs are offered. The size of the fixed cost impact can be fairly easily estimated and posed in the form of an elasticity. Additional study is needed to verify the appropriate range for the elasticity impacts.
Using a highly simplified analysis, the combined fixed cost impact and the benefits of lower EE costs produces an estimate of 5% increases in price for kWh equivalents, in total, over a 10 year horizon if all projected demand growth in the US economy is supplanted through additional DSM programs. There has been no attempt in this paper to demonstrate that this level of DSM penetration is feasible. However the recent McKinsey study and a variety of state DSM feasibility studies indicate that the additional DSM penetration of 16.4% over 10 years is at least feasible. The challenges for regulators are many. Two significant challenges are: 1) finding ways to incent IOUs to invest more in DSM programs in order to begin correcting the market imperfections; and, 2) addressing equity concerns associated with pricing impacts while moving to optimize DSM investments.
Additional Research Areas. Developing policy choices that mitigate the fixed cost penalty from DSM programs is the most impactful area for additional study. Policy implications from adopting straight fixed/variable pricing structures and implementing programs that allow for a transfer system that addresses equity concerns need to be researched on a broader scale.
The impact of significant growth in DSM program investments on costs is worth additional study. Technology adoption curves often show declining costs associated with a growth rate of the magnitude studied here. Growth should lead to declining returns as more marginal DSM programs are implemented and this needs to be understood.
The 'smoothing' benefits of looking at demand growth nationally rather than on an individual IOU basis would also be interesting. This work would allow for estimates of the fixed cost penalty nationally. Irrespective of this work, however, the impacts on customers will still boil down to individual IOU level studies.



