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Customer Choice and Direct Delivery: Competitive Options for Commercial Customers - Large Customer's Perspective
1. N A T I O N A L E X P E R T I S E . R E G I O N A L L A W F I R M . | P A R S O N S B E H L E . C O M
Customer Choice & Direct
Delivery: Competitive Options
for Commercial Customers –
Large Customer’s Perspective
Vicki M. Baldwin
Parsons Behle & Latimer
Electric Utility Rulemaking Conference – March 15, 2016
2. Disclaimer
All views and opinions expressed in this
presentation are those of the presenter and
not necessarily those of Parsons Behle &
Latimer or any clients of PB&L.
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3. Client Characteristics
Take at transmission level
Metered service
High load factor
Loads not seasonal
Sophisticated in business
Electricity second largest expense
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4. Regulation
Purpose
First principle
Regulatory leniency
– Shifts costs to rate payers
– Shifts risks to rate payers
– Culture of entitlement
– Cost of capital advantage
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5. Shifting Risks from Utility
to Ratepayers
Future test period
Recovery of demand side management costs
Single-item rate case for capital investment
projects
Annual pass-through of fuel and purchased
power costs
Pre-approval for recovery of energy resource
costs
For 2004 – 2012 → ROE of 10.25% to 10.7%
Current ROE 9.8%
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6. 6Electric Utility Rulemaking Conference – March 15, 2016
8.95%
3.81%
7.62%
2.50%
2.72%
7.43
3.52%
4.65%
6.07%
3.08%
3.36%
1.47%
Date Effective
Industrial Rate Increase over Time
3/1/05 12/11/064/1/04 6/1/07 8/13/08 5/8/09 2/18/10 1/1/11 10/12/12 9/1/13 9/1/14 9/1/15
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5.82
6.63 6.81
7.57
8.11
4.16
5.48
4.54
3.38
3.57
4.04
2.7
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
Dates
Henry Hub Natural Gas Spot Price
U.S. Energy Information Administration
4/1/04 12/11/063/1/05 6/1/07 8/13/08 5/8/09 2/18/10 1/1/11 10/12/12 9/1/13 9/1/14 9/1/15
11. Cost Allocation
Goal – cause and effect
Costs to serve not equal
More accurate pricing than cost allocation
Regulatory leniency
– Simplicity
– Gradualism
– Shifts costs to other classes
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12. 12 – CP & 75/25
Multi-state protocol
Utah class allocation
Residential and commercial
– Not metered – sampled
– More temperature sensitive
– Low load factor
Costs socialized across classes
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13. Energy Balancing Account
Carrying Charges
Monthly accounting but annual average
recovery
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14. Conclusion
Distributors and end users such as industrials
should have the ability to make market-driven
choices for electricity
Promotion of competition among electricity
suppliers will benefit all electricity consumers
and the nation by ensuring an adequate and
reliable supply of electricity at the lowest
reasonable price for everyone
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15. Thank You
Vicki M. Baldwin
vbaldwin@parsonsbehle.com
801.532.1234
www.parsonsbehle.com
201 South Main Street, Suite 1800
Salt Lake City, UT 84111
15Electric Utility Rulemaking Conference – March 15, 2016