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The Authority’s Response
Presentation to the Public Service Commission The Authority’s Response to PSC Orders 20/2013 and 21/2013 in Docket No. 289 and the Report on the Authority LEAC Factors for January 1, 2013 prepared by Georgetown Consulting Group Tuesday February 12, 2013
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Principal Issues with the GCG Report
Reasons for the Filed Q LEAC Rate Increase GCG: Predominantly (82%) due to efficiency assumptions Reasons for the Deferred Fuel Balance GCG: Authority’s own making Efficiency of Plant Operations GCG: Never meet efficiency targets GCG: Efficiency below standards GCG: Acceptable level of efficiency Average system heat rate of 9,500 to 10,000 Btu/kWh GCG: The Authority burns too much fuel About 50% more fuel than an average system or 80% more than an “efficient system”
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GCG Misstates Reasons for the Filed Q3 2013 LEAC Rate Increase
From GCG Calculations GCG Report w/Math Errors Corrected * Higher Fuel Prices (14%) 26 % More Realistic System Operating Efficiency Related Assumptions 82 % 40 % Lower Sales Forecast 2 % Deferred Fuel and Other Charges 32 % Total of Above 100 % LEAC Rate Increase Effect * * On Customer using 400 kWh/mo. $/Month % Increase % of Total $ 3.31 1.7 % 25 % $ 5.40 2.8 % 41 % $ 0.23 0.1 % 2 % $ 4.18 2.2 % 32 % $13.12 6.8 % 100 % * From GCG worksheet; corrected and effects of lower sales forecast reflected. * * From analysis of Quarter 3, 2013 LEAC filing.
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The Essence of the Deferred Fuel Balance
The Deferred Fuel Balance has resulted from: Actual Fuel Costs EXCEEDING Revenue from the Fuel Component of the LEAC Rate over an extended period
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A Long Term Issue - still trending in the wrong direction
Source: From LEAC filing worksheets and financial records.
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Reasons for the Deferred Fuel Balance
Differences between Actual and Estimated fuel prices generating unit status changes/outages system average heat rates fuel consumption per kWh produced inverse of efficiency station use and line losses fuel used to produce water weather and customer loads The Deferred Fuel Balance is not a situation Of the Authority’s own making As indicated in the GCG Report
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Decisions have Impacted the Deferred Fuel Balance
Since July 2007, the level of the LEAC Rates approved by the Commission based on GCG recommendations Has been $55 million LOWER than filed by the Authority Over that time, the Deferred Fuel Balance grew by approximately $30 million and is at $52 million as of Dec 2012
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Decisions have Impacted the Deferred Fuel Balance
Fuel price driven decision regarding LEAC Level for Quarter 1, 2013 Basis Fuel Price per Barrel Filed by the Authority $117 Recommended by GCG & Approved by the Commission $101 Actual $123 The major contributor to the deferred fuel balance increasing by $7 Million in that Quarter
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Impacts of Cash Constraints
Constraints Increase Costs Deferred Maintenance/ Improvements Unscheduled Outages Increased Maintenance Costs Less Efficient Unit Operations
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Efficiency of Operations
Misleading Concept 1 in GCG’s Report (page4): the Authority’s efficiency is: well below the equipment manufacturers’ standards for operation; well below industry standards for the plants on the Authority’s system; and below the standards set by the Authority’s consultants, Harris Group. Key Facts: It is inappropriate and misleading to compare to the efficiency data from manufacturers and other generation systems. Without appropriate adjustments The efficiency of the Authority’s operations has been reasonably consistent with the Harris Report. Based on adjusted manufacturer data
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Key Factors System Efficiency Generating units Characteristics
Availability Mode of Operation Simple cycle Combined cycle (with HRSG) Combination of units operated Level of loads Relative to generation unit size Fuel consumed in Water Production
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Efficiency Consistent with Harris Report
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Efficiency Consistent with Harris Report
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Efficiency Consistent with Harris Report
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Efficiency of Operations
Misleading Concept 2 in GCG’s Report: “…the level of production efficiency attained [by the Authority] is far below the industry average, and even further below current trends in production efficiency. An acceptable level of system efficiency would be in the range of 9500 to 10,000 BTU’s/kWh, meaning that the Authority burns about 50% more fuel than an average system or 80% more than an efficient system.”
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Harris Report Inconsistent with GCG’s “Acceptable Level”
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Comparisons to Guam’s Power Authority
2010 Average System Heat Rate * (Btu per kWh Produced) Guam ,670 The Authority ,200 Inappropriate to conclude that the Authority should: Achieve similar efficiency Burn significantly less fuel * Source: Page 8, Guam Initial Technical Assessment Report produced under direction of the U.S. Department of the Interior Office of Insular Affairs by the National Renewable Energy Laboratory (NREL) - NREL/TP-7A April 2011.
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Significant System Differences
Misleading Significant System Differences GPA is a much larger single system ~ 4 to 5 times the size of the STT & STX systems GPA has more efficient generation units Due to size and environmental permitting issues the Authority’s production of water Adversely affects the efficiency of the Authority’s electric system the Authority’s load characteristics Relatively more costly to serve
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Source: Prepared by nFront Consulting with PRMG, Inc
Source: Prepared by nFront Consulting with PRMG, Inc. Data from the Authority and the Guam Initial Technical Assessment Report produced under direction of the U.S. Department of the Interior Office of Insular Affairs by the National Renewable Energy Laboratory (NREL) - NREL/TP-7A April 2011.
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The Authority and GPA are Very Different
Bottom Line on the Difference in Installed Generating Unit Efficiency Authority GPA Energy Produced from Base Load Units Avg. Heat Rate less than 10,000 Btu/kWh NONE Target enough to serve 90% of GPA’s load each year Source: Prepared by nFront Consulting with PRMG, Inc. Data from the Authority and the Guam Initial Technical Assessment Report produced under direction of the U.S. Department of the Interior Office of Insular Affairs by the National Renewable Energy Laboratory (NREL) - NREL/TP-7A April 2011.
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Past Study: SLOW SPEED DIESELS NOT AN OPTION FOR the Authority
Slow speed diesels have much better heat rates and can burn cheaper, dirtier fuels Air impacts in our locale would be significantly greater than from existing turbines No pollution control technology has been demonstrated to reduce NOx emissions enough to meet air quality requirements Air permits not possible at existing plants Source: February 2005 report by MACTEC titled "Engineering Report on Feasibility of Obtaining Air Permits for Slow Speed Diesel Engines”
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Daily Load Characteristics
The Authority’s load is relatively more costly to serve Greater variance in load level From minimum to maximum loads Much smaller load in proportion to generation unit sizes Causes significantly less efficient use of available generation resources Source: Prepared by nFront Consulting with PRMG, Inc. Based on data from the Authority and the Guam Initial Technical Assessment Report produced under direction of the U.S. Department of the Interior Office of Insular Affairs by the National Renewable Energy Laboratory (NREL) - NREL/TP-7A April 2011.
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The Authority’s Load Characteristics Adversely Impact Efficiency
Source: Prepared by nFront Consulting with PRMG, Inc. based on hourly data supplied by the Authority.
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US Utilities - Not a Useful Benchmark
Source: Prepared by nFront Consulting with PRMG, Inc. based on Table 8.2b Electricity Net Generation, Electric Power Sector, for 2011, US EAI/Annual Energy Review 2011 published September 2012.
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Overview - System Changes Considered
2005 Harris Report System base line condition assessment CFB PetCoke & STX/STT HRSGs 2008 R. W. Beck Report Cost and dependence on oil CFB PetCoke, wind, HRSGs, LNG (future) Plans that would lower total costs ---- and improve efficiency to the levels deemed acceptable by GCG? NONE !!!!
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Changes Planned and Under Consideration
Improve the existing system resources Diversify sources of fuel including liquefied petroleum gas, liquefied natural gas, and/or coal Electrically interconnect STT to Puerto Rico through an undersea transmission line Develop renewable energy resources Pursue biomass and ocean thermal technologies
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LEAC Filing Improvements
Document data sources/assumptions Used within the LEAC filing Clarify and comply with Minimum Filing Requirements Revise LEAC Spreadsheets to improve Transparency Reconciliations Differential Analysis
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LEAC Filing Improvement Process
Progressively Improve Basis for Fuel Cost Projections Fuel Prices Unit availability System efficiency Reflect updates to sales projections Provide narratives Key assumptions and balances Proposed methodology changes
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The Bottom Line The GCG Report
Misleading and not productive Should be rescinded The Authority is improving the LEAC Filing Efficiency assumptions Documentation and process System efficiency improvements will come from Improving our existing Resources Implementing more cost effective resources and fuel diversity The Authority’s cost recovery is key To improving future costs and reliability
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