- Regulatory strategy and litigation support
- Large energy user services
- Energy markets and financial analysis
- Energy and environmental policy
- Cost of service and rate design
- Distributed energy resources
- Transmission planning and pricing
- Resource planning and procurement
E3 has provided procurement and rate-making advice to Wyoming’s Lower Valley Energy (LVE) since 2001. Our long-term procurement plans have carefully addressed LVE’s need to mitigate cost increases due to changes in either market prices of energy or Bonneville Power Administration’s rates. We have also helped LVE assess the merits of different rate structures and compare the value of building generation in its own service territory with the costs of building new transmission facilities to access alternative power sources. Most recently, we provided an independent evaluation of the costs and benefits of a potential merger with a neighboring co-op utility.
E3 supported San Diego Gas & Electric (SDG&E) in its successful application to the California Public Utilities Commission to launch a pilot program that uses pricing to efficiently integrate electric vehicle (EV) charging in an increasingly renewable grid without contributing to local distribution capacity shortages. SDG&E devised a dynamic vehicle grid integration rate to encourage EV charging at times when high renewable generation depresses wholesale energy prices. The tariff also discourages charging during peak distribution hours. E3 used its EV Grid Impacts Model to show that EV owners that shift their charging in response to the proposed rates would reduce their per-vehicle charging costs to under $600 annually from around $1,400 per year on the current time-of-use rate. The modeling used projected wholesale energy prices in high-renewable scenarios developed using E3’s stochastic production simulation tool, Renewable Energy Flexibility Model (REFLEX). The commission approved a modified version of the proposed program in 2016, and SDG&E is now implementing the pilot.
E3, working with the New York State Energy Research and Development Authority (NYSERDA), developed an innovative retail electric rate design to encourage beneficial customer investment in distributed energy resources (DERs), a leading goal of the New York Public Service Commission’s Reforming the Energy Vision initiative. Our conceptual full-value tariff (FVT) has three components: a customer charge, a size-based network subscription charge, and a time-varying kWh price. The network subscription charge may vary by location to reflect local transmission and distribution costs. We modeled customer response to the FVT to assess its impact on the value proposition of DER technologies, such as energy storage, smart thermostats, and smart vehicle charging. The analysis showed that the FVT can yield savings from measures that are not encouraged under existing rates, while still compensating solar PV and energy-efficiency measures in high-value locations. The FVT conceptual framework underpins the Smart Home Rate demonstrations that New York’s investor-owned utilities filed with the commission in February 2017.
Our work for Vancouver-based BC Hydro began with the design and implementation of an innovative multipart rate structure that included customized baselines for each of its 100 largest industrial customers. In 2008, E3 began assisting the utility with developing and implementing inclining block rate structures to encourage conservation. These ranged from a simple, two-step residential inverted block rate to more-complex baseline structures for commercial customers. Our process included surveying default rates for large general service and residential customers in other markets, analyzing usage characteristics, examining class segmentation options, and ensuring that our proposed rates adhered to BC Hydro’s cost of service principles and regulatory rate-making framework. E3 also developed materials for customer engagement, solicited feedback through moderated customer sessions, and provided expert witness testimony.
E3 has supported electric rate design in Hawai‘i since 2005. Currently, E3 is assisting Hawaiian Electric Company (HECO) on next-generation retail pricing strategy and rate designs that align with the state’s goal of meeting its 100 percent renewable portfolio standard (RPS) requirements in a way that encourages cost-effective deployment of customer-owned distributed energy resources. HECO first retained E3 to recommend a strategy for developing rates that would encourage conservation to mitigate the impact of high electricity supply costs on its customers. We recommended a three-tier inclining block structure, which is still in place, to minimize increases on small customers and provide conservation incentives to large customers. We also helped get the rate approved, preparing direct testimony and presenting to the utility’s board of directors.
Litigation: pipeline toll restructuring proposal | Canadian Association of Petroleum Producers, 2013–14
The Canadian Association of Petroleum Producers (CAPP) retained E3 to develop regulatory strategy and testify before the Canadian National Energy Board (NEB) in proceedings opposing TransCanada’s proposal to restructure tolls on the Mainline, which transports natural gas from western Canada to eastern markets. TransCanada had proposed restructuring tolls to maintain the line’s economic viability, as throughput declined due to soaring shale gas production in the northeastern U.S. The proposed change shifted fixed costs away from shippers, who were direct customers of the Mainline, toward producers, who were supplying gas to TransCanada’s own distribution network. Our alternative on behalf of CAPP offered a performance-based incentive with some pricing flexibility and balancing accounts that allowed TransCanada a reasonable opportunity to increase throughput and revenues and recover its investment. The NEB ultimately rejected TransCanada’s proposal in favor of CAPP’s, averting a shift of $300 million per year in fixed costs to western Canadian gas producers.
E3 created a public tool for the California Public Utilities Commission (CPUC) to inform the development of a successor to existing net energy metering (NEM) tariffs for eligible customer-sited renewable generators. This tool helped the CPUC and stakeholders balance legislative directives to design tariffs that maintain sustainable growth of such generation and ensure that total benefits to customers are approximately equal to total costs.
The tool lets users evaluate different rate designs, simulating their impact on adoption of customer-sited PV and on bills for all ratepayers, while accounting for feedback effects on future rates and life-cycle cost-effectiveness. Providing a common model to all parties allowed the CPUC and stakeholders to focus on fundamental differences in proposals and scenarios, rather than on disagreements and confusion over model differences.