Capacity Allocation Methodology E3’s Avoided Cost Calculator allocates capacity value using a proxy for relative loss-of-load probability (rLOLP) based on CAISO system loads. The value of capacity is allocated to the top 250 load hours of the year in inverse proportion to the difference between the calendar year’s peak load (plus the operating reserve margin) and the load in each hour: 1 ai 1 mL P Li 250 1 h 1 1 m L P Lh 1 where ai = hourly capacity allocator in hour i LP = peak load in calendar year Li = load in hour i m = operating reserve margin This allocation methodology results in hourly allocators for the top 250 load hours that sum to 1.0; no capacity value is allocated to hours with loads below the threshold set by the load hour 250. Current Avoided Cost Calculator Allocation The version of the Avoided Cost Calculator submitted with the DR Protocols calculates capacity allocators based on a calendar year of load data stretching from July 1, 2009 through June 31, 2010. This calendar year was selected because it is correlated with the MRTU day-ahead and real-time prices used to value energy in the calculator. The single year of load data used results in the allocation of capacity to only three months of the year (July-September); stakeholders have expressed concern that such a narrow window of capacity allocation is not appropriate for demand response. Figure 1 shows the hourly and monthly allocations of capacity value currently calculated in the Avoided Cost Calculator. Figure 1. Current allocation of capacity value in Avoided Cost Calculator 45% 40% Monthly Allocation of Capacity Hourly Allocation of Capacity (Sorted in Descending Order of LOLP) 2.5% 2.0% 1.5% 1.0% 0.5% 35% 30% 25% 20% 15% 10% 5% 0.0% 0% 0 100 200 300 400 500 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec PG&E’s rLOLP as an Alternative for Capacity Allocation PG&E has provided the hourly relative loss-of-load probability calculated by its proprietary model as an alternative to the allocation based on loads. PG&E’s rLOLP allocates capacity value to a wider span of months, including small allocations to January, February, and April. PG&E’s rLOLP allocation is summarized below in Figure 2. Figure 2. The allocation of capacity value resulting from PG&E's rLOLP model results. 45% 40% Monthly Allocation of Capacity Hourly Allocation of Capacity (Sorted in Descending Order of LOLP) 2.5% 2.0% 1.5% 1.0% 0.5% 35% 30% 25% 20% 15% 10% 5% 0.0% 0% 0 100 200 300 400 500 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Multi-Year Average Capacity Allocation As an alternative to the single year of load data used to calculate the original allocators and to using the results of PG&E’s proprietary rLOLP model, E3 proposes the use of several years of load data to calculate average monthly capacity allocators. By calculating allocators using load data from 2006-2009 instead of a limited one-year period, E3’s modified methodology allocates the value of capacity across a wider set of months, capturing the potential diversity of peak constraints. While this approach does not match PG&E’s rLOLP calculation perfectly—particularly in May and June, when constraints are driven as much by supply-side conditions as by demand—it provides a reasonable and improved approximation of this curve and maintains the advantage of computational transparency. The allocators calculated based on the 2006-2009 loads are shown in Figure 3. Figure 3. Allocation of capacity based on an average of 2006-2009 load data. 45% 40% Monthly Allocation of Capacity Hourly Allocation of Capacity (Sorted in Descending Order of LOLP) 2.5% 2.0% 1.5% 1.0% 0.5% 35% 30% 25% 20% 15% 10% 5% 0.0% 0% 0 100 200 300 400 500 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Calculation of Capacity Residual The Avoided Cost Calculator calculates the value of capacity using a new combustion turbine as the proxy resource for capacity. The value of capacity is calculated as the capacity residual: the real annualized cost of a new CT less the annual net revenues that generator could earn through participation in the real-time energy and ancillary services markets. Each of the components is calculated individually in the avoided cost model: 1. Real Annualized Cost of a New CT: The real annualized cost of a CT is calculated by levelizing the cash flow associated with a new CT using the real utility after-tax WACC. This cost is adjusted upward for inflation in each year. 2. Net Revenue in Real-Time Market: E3 assumes that the new CT will participate in the real-time energy market, dispatching in each hour if average real-time market price in that hour exceeds its operating cost. E3 has characterized the MRTU real-time market by analyzing data from 7/1/2009-6/31/2010 and dispatches the CT in each year using this market characterization: NRRT max 0, HRM ,h g m HRCT g m VOM 8760 h 1 where NRRT = net revenue in real time market HRM,h = real-time market heat rate in hour h HRCT = heat rate of a new CT gm = gas price in month m VOM = variable operations and maintenance cost 3. Ancillary Services Revenues: Ancillary services revenues are assumed to scale in proportion to the gross revenues earned in the real-time energy market. Based on data presented in the CAISO 2010 Market Report, the A/S revenues are assumed to equal 11% of gross real-time energy market revenues. E3 calculates the capacity residual in each year based only on the net revenues expected in that year—not on the real annualized lifecycle value of net revenues earned by a new combustion turbine. E3 has chosen this methodology for several reasons: 1. It is consistent with the approach used to calculate the capacity residual used in jurisdictions that use the capacity residual to set actual capacity market prices or capacity market price limits (NYISO and PJM); 2. It is more appropriate as a short-term marginal value of capacity, as the marginal capacity resource would not be contracted on a long-term basis and, in a competitive market, would accept a capacity payment based on current market energy conditions; and 3. It is more consistent with the valuation of energy in the avoided costs, which does not use a lifecycle approach of a new generator but is based on current market conditions and extrapolations thereof. The capacity values calculated based on this methodology in the three years of the upcoming DR program cycle are shown in Table 1. Table 1. CT residual calculations using single-year net revenue. CT Residual Calculation, Current Methodology Real Annualized CT Fixed Cost Annual Gross Energy Revenue Annual Gross A/S Revenue Annual Operating Cost CT Residual Costs in nominal $/kW-yr 2012 191.80 ($108.65) ($12.03) $48.57 119.69 2013 195.63 ($121.01) ($13.40) $56.54 117.77 2014 199.55 ($130.86) ($14.49) $62.12 116.31 Nonetheless, E3 recognizes the alternative possibility of calculating the capacity value based on the real annualized lifecycle net revenues. Because the value of energy is expected to escalate faster than the cost of plant construction this alternative methodology will result in a lower value of capacity in all years. The resulting capacity values are summarized for the upcoming three-year program cycle in Table 2. Table 2. CT residual calculations using real annualized lifecycle net revenues. CT Residual Calculation, Alternative Proposed Methodology Real Annualized CT Fixed Cost Lifecycle Annualized Gross Energy Revenue Lifecycle Annualized Gross A/S Revenue Lifecycle Annualized Operating Cost CT Residual Alternative Costs in nominal $/kW-yr 2012 191.80 ($135.01) ($14.95) $64.51 106.35 2013 195.63 ($140.85) ($15.60) $67.65 106.84 2014 199.55 ($146.21) ($16.19) $70.41 107.55 Figure 4 shows the results of the two alternatives: the higher capacity value is based on a residual calculated using single-year revenues, while the lower capacity value is based on a residual calculated using real annualized expected lifecycle revenues. Figure 4. Capacity value alternatives for DR capacity valuation. Capacity Residual (nominal $/kW-yr) $160 $140 $120 $100 $80 $60 $40 Calculated with Annual Net Revenue $20 Calculated with Annualized Lifecycle Net Revenue $0 2010 2012 2014 2016 2018 2020