Utility 2.0: NY Utility Regulators Should Consider Change to "Formula for Success"
Acquire more customers, sell more electricity. This primary formula has fueled the runaway success of utility companies in America, as well as the rest of the world, for well over a hundred years.
But today, in an era when customers are technologically savvy, price conscious, and environmentally aware, more families are pursuing opportunities that will cut electricity bills and carbon emissions. Options once considered fringe, like installing rooftop solar panels and driving electric cars, are now becoming so mainstream that utilities everywhere are seeing their bottom lines crunched and even fear for their survival. The electricity sector needs a new formula that can account for these changes, while still providing reliable, safe, and affordable electricity for all.
As a result of increased energy efficiency and heavier reliance on local, distributed energy resources, it’s clear our country is moving toward a reality in which less electricity will come from centralized, fossil fuel power plants. At the same time, customers want utilities to continue providing basic electricity services while allowing them to benefit from new energy-efficient solutions and clean technologies in order to waste less electricity and generate our own power.
How will this be possible? A key first step is moving away from the existing regulatory paradigm, which rewards utilities for investing in more power stations and equipment, to a model that rewards utilities for the performance we seek today.
The New York Public Service Commission (Commission) recognizes that the traditional utility business model – which rewards utilities with investment returns – leaves little opportunity for utilities to innovate, stating in its “Reforming the Energy Vision” (REV) Staff Report: “Current ratemaking provides few incentives for utilities to innovate or to support third-party innovation, to address the current challenges in ways that promote a more efficient system and benefit consumers.”
Utilities will be evaluated on clean energy, customer engagement
In EDF’s recommendations to the Commission, we propose an enhanced version of performance-based regulation, or what we refer to as PBR+, that removes the link between utility earnings and their investments in infrastructure. With PBR+, a utility will be evaluated not just on how well it provides standard electricity service, but also on whether it delivers benefits to the customer and to the environment. Today, the Commission uses metrics such as reliability, safety, and quality of service to regulate utilities, all of which provide a strong foundation for evaluating performance and will still be used. But the Commission plans to establish new metrics that will also take into account the availability of clean energy solutions as well as how much flexibility a customer has to adopt them. It will be necessary for the Commission to establish these new performance metrics and also devise a standard method for evaluating a utility’s performance against them linked to the utility’s compensation.
In establishing these new metrics, the Commission must answer a number of questions, most notably: What outcomes does New York’s REV proceeding seek to achieve? From the start of the landmark proceeding, the state identified four categories of potential outcomes to come from the effort to reform the utility business model:
- Advanced clean energy,
- Customer engagement,
- Reliable and resilient system, and
- Operational efficiency.
Metrics might be applied differently
While the same metrics will apply to all utilities within New York State, they might be applied differently to utilities based on individual circumstances. Factors such as the number of homeowners versus renters, population density, and types of customers (e.g. industrial, commercial, residential) could influence the solutions utilities are able to pursue, allowing some utilities to perform better under certain metrics than others.
In defining these metrics, it will be important to understand what value customers will place on the outcomes, and some metrics may by their very nature be exceedingly difficult to accurately value. Three metrics that align with the state’s policy direction, as well as customers’ needs, are greenhouse gas emissions reductions, better resiliency, and improvements to customer service. Such metrics would help put New York on a pathway to achieve its goal of an 80% reduction in total carbon emissions by 2050.
Executed properly, a utility’s earnings would no longer be considered an entitlement, but would be based entirely on its performance according to the Commission’s new metrics. It is our belief that PBR+ is the best way to motivate utilities to achieve the outcomes New Yorkers desire, while still meeting today’s challenges.
Last month, EDF filed comments (Track 1 and Track 2) in New York State’s historic ‘Reforming the Energy Vision’ (REV) proceeding to re-evaluate the longstanding utility business model in light of a rapidly changing energy sector. We recommend: 1) transitioning from traditional rate of return regulation to performance-based regulation; 2) fully valuing all costs and benefits associated with distributed energy resources; 3) removing barriers to non-utility entities participating in energy service markets; and 4) requiring the utility to optimize the load it serves.
Over the coming weeks, we will devote a blog post to examining each of these recommendations in depth. This blog post, the first in the Utility 2.0 series, discusses the merits of performance-based regulation.
As EDF's Director, New York Clean Energy, Rory Christian focuses on energy and clean air in New York. Rory works with state and city officials, the Public Service Commission, and large utilities such as Con Ed to develop policies supporting an evolving utility landscape. He also works with the Green Bank and private sector clean energy companies to develop opportunities for financing clean ...
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