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Alvarez, Paul J.

Publications and source records attributed to Alvarez, Paul J..

Alternative Ratemaking in the US: A Prerequisite for Grid Modernization or an Unwarranted Shift of Risk to Customers?

With increasing frequency, investor-owned electric utilities are requesting preferred cost recovery for "grid modernization" in multiple forms, from multi-year rate plans to riders. Utilities' claims that massive grid investment is necessary, and that exceptional investment requires exceptional cost recovery, are typically accepted by policymakers with little challenge. It is difficult for policymakers to resist the siren call of grid modernization's perceived outcomes, from improved reliability and resilience to reduced risks to safety and new customer technology adoption (electric vehicles, distributed energy resources, and more). This paper provides a contrarian viewpoint that is virtually absent as policymakers consider alternative ratemaking practices. It introduces the possibility that excess grid investment in the name of modernization is not only possible, and economically harmful, but has already occurred, encouraged by alternative ratemaking. It provides examples of common grid modernization expenditures the authors have identified as cost-ineffective in the course of their work. It also describes traditional grid planning practices with proven ability to address changing requirements over time, calling into question the need for exceptional grid modernization investment plans. Most important, the paper explains the moral hazard inherent in alternative ratemaking, and the fundamental shift in ratemaking risks and responsibilities from utilities to customers that results. The perspectives this paper presents are critical for policymakers to understand before adopting, extending, or expanding alternative ratemaking practices in their respective jurisdictions.

ENERGY PLANNING, POLICY, AND ECONOMY,POWER TRANSMI↗

Utility Regulation Through Legislation: A Cautionary Tale for Legislators, Regulators, Stakeholders, and Utilities

State legislatures in the U.S. are becoming increasingly involved in utility regulation. While state utility legislation can expand regulator authority, for example in the case of renewable energy or energy efficiency standard administration, it can also reduce it. Given the challenging nature of for-profit monopoly regulation, state utility legislation often reduces regulator authority unintentionally. This editorial begins with an examination of the outcomes of state legislation related to baseload generation in the U.S. and the resulting impacts to customers, shareholders, and state economies. The record indicates that utility regulation through state legislation has caused significant economic harm, generally by encouraging for-profit utilities to make riskier investments. A description of more recent state legislation involving distribution grids is presented, along with evidence that increases in grid investment encouraged by state legislation has not improved the reliability of U.S. for-profit utilities. The authors claim that features common to state utility legislation, particularly the requirement that utilities provide investment plans to regulators in advance, practically eliminates cost disallowance risk. This, in turn, reduces regulator authority despite legislative provisions intended to protect consumers. The authors hypothesize that the practical elimination of cost disallowance risk, combined with information and expertise asymmetry among regulators and stakeholders, encourages for-profit monopoly utilities to make grid investments that are not cost effective. The editorial concludes that legislators should avoid utility regulation through legislation, thereby preserving regulator authority, whenever possible. The authors also present their fifth annual Customer Value Ranking of U.S. investor-owned electric utilities. The ranking represents a comparison of the benefits utilities deliver to customers (measured by reliability performance and customer satisfaction) to the costs customers pay (measured by O&M and capital spending per customer).

ENERGY PLANNING, POLICY, AND ECONOMY,POWER TRANSMI↗