1st April 2007

The Wholesale Market: Competition and Security

From a consumer’s (and especially a small consumer’s) point of view,
the wholesale electricity market as it has developed has failed to control prices.

This is because competition at the wholesale level (as well as at the retail)
is ineffective.
Basically, there are too few competing generators (which wield sufficient market
power to inhibit others entering the market);
there is insufficient excess capacity to ensure effective competition;

New Zealand is probably too small to support an effectively designed to use complementary generation sources (hydro with thermal firming),
and is inherently not suitable for operating competitively.

For effective competition to exist, there must be excess capacity
(there must always be an unsuccessful offer at the margin).
This is not always the case in NZ.
During hydro shortages, the supply of electricity is sometimes
not enough to meet the demand and competition disappears.

During these times the spot price of electricity rises well above
production costs. Contract prices follow, and, on the evidence of the
2001 and 2003 events become locked in at higher levels even
when the shortage is over.

As well, to prevent gaming, there must be sufficient excess capacity to
prevent any producer cornering the market by withdrawing capacity from it.

Either of the two largest generators in NZ has the ability to do this;
either could withdraw enough capacity to cause a shortage, and then sell
the output of its remaining capacity at rationing prices
(incidentally, this type of gaming occurred in Victoria in the summer of 2000).
We believe there have been instances of this happening in a minor way. Further, NZ’s generation mix does not suit competition.
Different forms of generation
(eg hydro, gas fired combined cycle, gas or coal fired steam)
have different production costs and therefore cannot compete head on.

Usually hydro and geothermal are cheaper than fossil fuelled thermal generation,
and are dispatched first.
Combined cycle, in the next higher cost layer, is often at the margin
because it is cheaper than gas or coal fired steam generation, which is only
used when the demand cannot be met by cheaper plant (in winter, and during shortages).

The ownership of the generation in each cost layer is dominated by a different company.
Because of this, it is more a question of the different companies complementing each
others’ generation, rather than competing with it
- of course, that was how the system was designed to operate.

Therefore, we do not consider the wholesale electricity market in NZ to be
effectively competitive at this time,
and we do not believe there is any simple way in which competition can be increased.

For example, further generator splits into smaller units does not seem practical,
because the generation system contains a number of integrated systems
(the Waitaki, Clyde and Taupo hydro systems, Huntly Power Station)
which could not be broken up.

This limits the number of effective competitors (and also, incidentally,
determines the amount of excess capacity needed to avoid gaming).

As well, the existing market system has failed to deliver security of supply.
Generators have no incentive to build adequate generation to achieve an economically
optimum balance between the cost of shortages and the cost of additional capacity.
That would reduce the number of shortages that cause high spot prices,
reducing their revenues and simultaneously increasing their capital investment.

The present tight capacity margin is financially advantageous for the generators,
but disadvantages the national economy both directly (by reducing GDP during shortages)
and indirectly (by reducing business confidence in the reliability of the electricity supply).

Finally, State ownership of about two thirds of the generation capacity
(not to mention the retail market) has introduced a major (and unnecessary)
distortion in the market.

At present, the State does not behave like a conventional equity investor.
It does not provide equity for capacity expansions; indeed, it removes equity
through the special dividends it receives.

That it tacitly condones the exploitation of consumers to provide funds for its social
welfare policies

(why should electricity consumers bear this burden, rather than the nation as a whole?)
has been acknowledged by both the then Minister of Energy , Pete Hodgson1 and Dr. Cullen2.

One aspect of this is the significant revaluations of hydro generators, which are calculated
from the present value of their future revenue streams based on prices set by the
marginal (thermal) generators; and serve to mask the excessive returns their owners
(predominantly SOEs) make on assets which were originally paid for by consumers
through capital levies included in the bulk tariff.

Remedies

The view of the majority of Greypower members, and members of the consumer organisations
Greypower is associated with, seems to be that a return to a NZE-type industry structure
would solve the present problems.
However, even without any detailed analysis of the costs and benefits of such a change,
it is extremely unlikely that this will happen; so we must consider how the present structure
needs to be modified to overcome the manifest problems consumers are experiencing.

From this viewpoint, the problems are not so much in the structure of the wholesale market,
as in the structure of the generation industry.

The basic problems of too little effective competition and too little excess capacity
have been discussed above.
Both lead the major symptom of excessively volatile spot prices during hydro shortages,
which directly damage the economy and also provide the generators with the opportunity
to raise retail and contract prices.

Our analysis3 indicates that the spot price volatility that occurred between
October 2005 and April 2006, for example, gained the generators an extra $180M,
although there was never less than five weeks usage margin above the minzone;
and the risk of non-supply was infinitesimal.

Our conclusion is therefore that the volatility was caused more by the generators’
opportunism than by a real need to ration usage by raising prices.

We need then to find ways of reducing this excessive volatility.

Most of the remedies lie in changing the structure of the industry - more capacity, and
controls both regarding pricing and capacity additions.
Also, instituting conservation campaigns as soon as the spot price rises above the
marginal production cost would both dampen the volatility and inform the public of the risks.
As well, the NZIER has proposed that retail tariffs could reflect spot prices,
with the same effects.

However, within the market itself, mandatory hedging, for example,
could reduce the effects of spot price volatility.

Further, the Vickery auction system that is used in NZ (where the marginal offer sets the
price for all the electricity dispatched) means that the generators in the lower cost bands
can make low offers in order to get dispatched (geothermal must run,
hydro tries to avoid spilling), since they are paid the strike price.

If generators were paid their offer price, the low cost generators would offer in at higher prices,
but still low enough to ensure dispatch.

This would bring them closer to the margin, and perhaps have some effect on the
degree of competition.
It should also lower the average price and would inform the public of the individual
generator’s price responses, which would be likely to inhibit excessive volatility.

Conclusion:

What’s best for the generation industry and the SOEs,
is not necessarily best for New Zealand Incorporated

1 As Minister of Energy, Hodgson told a woman who asked him at a public meeting why
electricity prices were so high,: “In order to pay your pension”.

2 Cullen has said publicly that if the State’s returns from electricity fell,
revenue from another source would need to be found for welfare policies

3 See Security of Supply Submission to the Security Advisory Group of
the Electricity Commission dated 11/6/06

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