The DOE has published on their site (here’s my pdf) proposed modifications to the EPIRA Implementing Rules and Regulations that are intended to permit the utilities to implement automatic pass-through of certain cost increases and decreases “that are brought about by factors beyond the control” of the utility [such as exchange rate fluctuations and fuel costs].
But of course, these are under the control of the utilities (aren’t they?) in that the utilities themselves make the initial decision to use foreign versus local financings and source supply from plants that burn fuel like gas/coal versus plants that don’t, like wind/solar.
That’s a bit tongue in cheek, but it’s meant to point out the fact that procurement and financing decisions made by utilities don’t impact just the cost consumers will bear, they impact the nature of risk that consumers bear. And much more attention needs to be placed on understanding this risk at the regulatory approval hearings.
The question is, who is going to advocate for and consider the consumers’ interest on risk? Indeed, who is equipped to do such advocacy or consideration?
Just exactly how much risk should ratepayers bear? Are utilities applying the best trade-offs of consumer cost versus consumer risk when they make procurement and financing decisions?