T +1 (202) 466 6790 F +1 (202) 466 6797 1700 K Street NW WASHINGTON DC 20006 United States of America T +61 (2) 9231 6862 F +61 (2) 9231 3847 Level 10, 1 Castlereagh Street How Can Regulators Promote Viable Renewable Generation in the Caribbean? SYDNEY, NSW 2001 Australia T +64 (4) 913 2800 F +64 (4) 913 2808 by Gianmarco Servetti Level 2, 88 The Terrace PO Box 10-225 WELLINGTON New Zealand T: +33 (1) 45 27 24 55 Organization of Caribbean Utility Regulators 8th Annual Conference F: +33 (1) 45 20 17 69 7 Rue Claude Chahu PARIS 75116 France Ocho Rios, Jamaica, 4 November 2010 ------------- www.castalia.fr Copyright Castalia Limited. All rights reserved. Castalia is not liable for any loss caused by reliance on this document. Castalia is a part of the worldwide Castalia Advisory Group. Agenda Barbados: unrealized renewable energy potential and carbon abatement curve Dominica: setting best practices rules while awaiting policy Jamaica: competitive bidding for utility scale renewables Cayman Islands: similar to Jamaica, but not yet implemented Using regulation for promoting viable renewables—utility scale and distributed scale 1 = Solar LSD/Natural Gas estimated fuel cost (US$0.06/kWh) and all-in cost (US$0.11/kWh) Commercially viable Economically viable Wind (On-Shore), 10000 kW 0.11 Biomass Cogeneration, 20000 kW 0.11 LSD/HFO fuel cost: US$0.14/kWh (utility), US$0.15/kWh (distributed)** 0.13 Wind (Off-Shore), 30000 kW Gas Turbines fuel cost: US$0.21/kWh** 0.13 Hybrid PV/Thermal, 2 kW 0.18 Municipal Solid Waste to Energy, 13500 kW Residential tariff: US$0.30/kWh 0.18 Seawater Air Conditioning, 2000 kW PV Thin Film Fixed, 50 kW = Commercial Scale 0.10 = Other * Solar Water Heater, 70 kW = Wind LSD/HFO all-in cost: US$0.19/kWh 0.09 Solar Water Heater, 2 kW = Utility Scale Good renewable energy potential in Barbados—currently unrealized 0.25 LCPV Single Axis Tracking, 5 kW LSD = low speed diesel Non-residential tariff: US$0.33/kWh 0.26 Wind, 10 kW 0.28 PV Thin Film Fixed, 2 kW 0.29 PV High-Efficiency Fixed, 50 kW PV High-Efficiency Fixed, 3 kW 0.36 HCPV Dual Axis Tracking, 5 kW 0.36 = Solar 0.23 HCPV Dual Axis Tracking, 50 kW = Small Scale 0.22 0.41 Wind, 1 kW - 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 * For “Solar water heater, 70kW” the comparator is fuel oil boiler. ** ‘Fuel costs’ include variable O&M costs, and are grossed up for losses (6.6%) for distributed technologies. Generation costs/tariffs based on oil prices US$100/bbl, and natural gas prices US$7/MMBTU. Natural gas generation contingent on planned Eastern Caribbean Gas Pipeline 2 = Wind US$/kWh 200 100 (200) • Save money • Reduce CO2e 3 • Good for the planet • But cost money • Who should pay? •Globally good projects 500 Wind, 1kW Solar PV (HCPV, Dual Axis), 5kW Solar PV (High Efficiency, Fixed), 3kW Wind, 10kW Solar PV (High Efficiency, Fixed), 50kW Solar PV (Thin Film, Fixed), 2kW Solar PV (LCPV, Single Axis), 5kW Solar PV (HCPV, Dual Axis), 50kW •Win-win projects Solar Water Heater, 70kW 400 Solar PV (Thin Film, Fixed), 50kW SWAC, 2MW Waste to Energy, 13.5MW Offshore Wind, 10MW Onshore Wind, 10MW 300 Hybrid PV/Thermal, 2kW Biomass Cogeneration 20MW - Solar Water Heater, 2kW Barbados carbon abatement curve—how to promote good technologies? US$26 per tCO2e •Non-viable projects (100) •SWAC = Seawater Air Conditioning; HCPV = High Concentration PV; LCPV = Low Concentration PV Dominica’s experience—setting best practice rules while awaiting policy Developing a least cost expansion plan to add utility scale renewable capacity to the system: DOMLEC to prepare an Integrated Resource Plan (IRP) and a Least Cost Expansion Plan (LCEP) IRC to use the results of the plans ‘as the basis for determining the quantum of and timing for the addition of new capacity’, and ‘promote the development of renewable energy resources for inclusion in the generation mix (…) to the extent that renewable energy or alternative energy are economically competitive with conventional generation technologies’* Developing rules for supply of renewable energy to the grid by DOMLEC and third parties: IRC envisages a process for adding new capacity whereby ‘all qualified organizations, including DOMLEC, submit proposals to the IRC for satisfying demand’* based on the IRP and LCEP IRC will ‘await the issue of the Government’s Policy on renewable energy before embarking on any far reaching decisions for the introduction of these technologies into the public electricity supply system’*— no policy statement yet that renewables should reduce electricity costs/prices Establishing a licensing regime: IRC can issue, monitor, amend, and revoke licenses (Electricity Supply Act, 2006) Preparing an Interconnection Code for distributed renewable generation IRC has stated that ‘DOMLEC is required to prepare and publish the procedure and terms for interconnection of renewable and alternative energy generation sources owned by third parties to the public electricity supply system’* * IRC, Regulatory Policy and Procedure—Adding Capacity to the Public Electricity Supply System, Decision, Document Ref: 2008/002/D 4 Jamaica’s experience—competitive bidding for utility scale renewables Legal basis: 1. Licence of Jamaica Public Service (JPS) mandates a tender process for procurement of new capacity >15MW 2. Office of Utility Regulation (OUR) to manage the bidding process Generation over 94% fossil-fuel based Renewables about 5.5% of generation—8 small hydro, one 20MW wind farm Situation Over 26M barrels of oil imported annually Policy Target 3. Agreement by which OUR does Least Cost Expansion Planning Distributed Scale: Feed-In Tariff? Utility Scale: Tender/LCEP Increase share of renewables generation to 11% by 2012, 12.5% by 2015, and 20% by 2030 Up to 640 GWh per year of renewable electricity (about 70MW firm power) By Independent Committee, in three steps: 1. Experience and financial assessment 1. JPS and OUR finalizing a Standard Offer Contract (SOC) 2. SOC to work under net billing (avoided cost set by OUR at US¢8.8 /kWh for energy only), not net metering Evaluation Negotiation 3. Tariff comparison—beat generation avoided cost of conventional capacity and energy (US¢/10.48kWh), +15% soft-cap price premium (overall 12.05¢/kWh) Highest-ranked bids invited to negotiate Award * All Island Electric Licence, 2001 2. Technical/environmental assessment Single or multiple awards up to 640 GWh per year 5 Cayman Islands’ experience—similar to Jamaica, but not yet implemented Electricity Regulatory Authority (ERA) responsible for the solicitation process for new capacity* based on least cost expansion plan prepared by Caribbean Utilities Company (CUC) CUC files Certificate of Need (size and timing of future requirements of firm capacity) ERA approves the Certificate and prepares solicitation package including criteria and timing for bid Encouraging renewables: ERA issues RFP to qualified bidders including CUC (which drafts PPA attached to RFP) ERA requests EOIs with minimum threshold requirements ERA assesses bids (issues generation licence to successful bidders other than CUC) CUC negotiates eventual PPA, to be approved by ERA before it is effective ERA can choose a bid that is not lowest cost, if consistent with evaluation criteria—if so, the CUC is compensated for the difference… ultimately by customers General solicitation process can include RE capacity, or there can be a RE-only solicitation CUC can also consider renewables projects on a case-by-case basis and negotiate PPAs, subject to approval by ERA and consistent with Government policy Government policy is to determine how to encourage utility scale and distributed RE, ERA to implement the policy Cost of non-firm renewable capacity (including distributed) is to be subject to a direct passthrough to customers—CUC can propose this, and if it increases cost, recommend and justify a limit on capacity; EAR to recommend to Government an appropriate policy framework * Government of the Cayman Islands, Transmission and Distribution Licence Granted to Caribbean Utilities Company, Ltd., 3 April 2008 6 Using regulation for promoting viable renewables—utility scale Least cost planning that includes renewables - Require utility to do least cost planning and include reasonable renewable energy options, assessed under various oil price scenarios - Regulator to check the least cost plan done by the utility rather than doing the least cost plan itself, preserving the utility’s independence in managing its business Options for adding new renewable generation that is economically viable - Auction: based on a least cost plan, it delivers ex ante approval of generation capacity through a competitive process - Developed by utility without auction: traditional regulatory check is ex post (for example, Barbados), but new technologies (especially for renewable generation) present uncertainties and risks—when utilities ask for ex ante approval, regulators should go with that - Regime for third party utility scale generation: Obligation for utility to purchase renewable power from third party suppliers when this is cheaper than providing the power itself and does not compromise power quality and reliability Utility calculates and publishes avoided costs Regulator checks avoided costs calculations, publishes best principles for PPAs, approves PPAs Third parties may challenge avoided costs and demonstrate they can generate reliable power at less Grid Code—utility to prepare, regulator to check it does not impose undue restrictions on third parties (also for distributed generation) 7 Using regulation for promoting viable renewables—distributed scale Disaggregated, cost-reflective tariff structure (utility develops; regulator approves): - Supply of energy Connection to the distribution system Provision of back-up and stand-by generating capacity Feed-in tariffs and metering rules - Set feed-in tariffs at avoided cost (they are not necessarily a subsidy) Cap distributed renewable capacity that can enjoy feed-in tariff Set period for feed-in tariff based on system lifetime Choose bi-directional metering/net billing over net metering Spain’s experience with feed-in tariffs (‘solar gold rush’) 2007 Law: US¢44 per kWh for 25 years to solar PV (10 times 2007 average wholesale price of US¢4), no cap Target: 400MW of solar power by 2010, and promote domestic manufacturing industry Result: 3,500MW by 2008, €126 billion in obligations to over 50,000 ‘solar entrepreneurs’ who often bought equipment abroad Source: Bloomberg Policymakers now considering pulling back… who will pay? 8 18 October 2010 Contact Gianmarco Servetti Manager, Castalia 1700 K Street NW Suite 410, Washington DC (United States) 202 4666790 (office), 202 550 3998 (cell phone) gianmarco.servetti@castalia-advisors.com 9