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      Utility Ratemaking

      Designing the Rate Once the Revenue Is Set

      Rate design converts a class revenue target into the charges a customer actually sees on a bill. The same class total can be collected in very different ways, and the choice among them decides who within the class pays more.

      Utility Ratemaking6 min readState lawCost allocation

      A row of mechanical dials on a gray electricity meter housing photographed close against a brick wall
      What the meter records determines which parts of a tariff a customer actually pays. — Wilfredor, CC0, source.

      The rule in short

      Once a commission has fixed each class's revenue responsibility, rate design determines the structure through which that revenue is collected. The components are a fixed customer charge, energy charges that may be flat or blocked, demand charges applied to larger customers, and time-varying or seasonal differentials. Federal law requires state commissions to consider a defined set of ratemaking standards.

      Rate design is the last step in a rate case and the first thing a customer notices. Once the commission has fixed how much revenue each class must produce, the tariff determines the structure through which that revenue is collected. The same class total can be assembled in very different ways, and the choice among them decides which customers within the class pay more and which pay less.

      The components of a tariff

      Nearly every retail tariff is built from three kinds of charge. A fixed charge is billed each period regardless of consumption and is usually called a customer charge, a basic service charge or a facilities charge. An energy charge is billed per unit consumed. A demand charge, applied to larger customers whose meters record it, is billed on the maximum rate of consumption during the period.

      The three track the cost classifications produced by a cost of service study, though imperfectly. Customer-related costs correspond to the fixed charge, energy-related costs to the energy charge, and demand-related costs to the demand charge. Because most residential meters historically did not measure demand, residential demand costs have conventionally been collected through the energy charge, which is the source of much of the design debate in that class.

      Whatever structure is chosen must produce the class revenue target. That constraint is what makes rate design a zero-sum exercise within the class: raising the fixed charge requires lowering the energy charge, and the effect is to move money from low-use customers to high-use ones. Nothing about the change alters what the utility collects.

      The fixed charge and what it should recover

      The level of the customer charge is contested in almost every case. Utilities argue for a higher charge on the ground that fixed costs should be recovered through fixed charges, which stabilizes revenue and aligns the bill with the cost structure. Consumer advocates argue for a lower charge on the ground that a high fixed component removes the customer's ability to reduce a bill through conservation and weighs most heavily on small users.

      Underneath the argument sits the classification question. If distribution plant is largely customer-related, a higher fixed charge follows. If it is largely demand-related, it does not. Because that classification depends on the contested minimum system analysis, the fixed charge debate is a continuation of the cost allocation debate rather than a separate one.

      A structural change and a revenue increase are separate decisions

      Commissions frequently receive a filing that proposes both simultaneously, and the combination obscures the effect. The disciplined approach is to evaluate the structure change on a revenue-neutral basis, showing what each customer would pay under the new structure at existing revenue levels, and then apply the increase. Presenting only the combined result makes it impossible to see which portion of a customer's change is attributable to which decision.

      Minimum bills operate as a partial substitute. A minimum bill provision guarantees the utility a stated amount per period, satisfied either by consumption or by a make-up charge, and it collects fixed costs from very small users without raising the customer charge for everyone. Its drawback is that it is invisible to most customers until an unusually low-usage month produces a bill that does not fall.

      Blocks, demand charges and ratchets

      An energy charge may be flat or arranged in blocks. A declining block charges less per unit as consumption rises, reflecting the historical view that additional units cost less to serve once fixed costs are recovered. An inclining block does the reverse and is adopted for conservation. Federal law directs state commissions to consider a standard under which the energy component of a rate may not decrease as consumption increases unless the decrease is cost justified.

      Demand charges apply where the meter records maximum load. They are stated per kilowatt of billing demand, and billing demand is usually not simply the current month's maximum. A ratchet provision sets billing demand at the higher of the current maximum or a stated percentage of the highest maximum recorded during a preceding period. The rationale is that capacity is reserved continuously for a customer whose peak occurs occasionally.

      Interruptible and curtailable rates form a related category. A customer that agrees to reduce load on notice imposes less capacity cost on the system and receives a discount for accepting the obligation. The federal standards direct consideration of offering such rates to industrial and commercial customers, and the design questions are the notice period, the number of interruptions permitted and the penalty for failing to curtail.

      ComponentBilled onCost it tracksWho bears more when it rises
      Customer chargeEach billing periodMeter, service, billingLow-use customers
      Flat energy chargeUnits consumedFuel and variable costHigh-use customers
      Inclining block energy chargeUnits, priced in tiersVariable cost plus policy objectiveThe largest users in the class
      Demand chargeMeasured maximum loadCapacity built for peakCustomers with low load factors
      Time-varying energy chargeUnits, priced by periodCost of serving at that hourCustomers concentrated in peak hours

      Standby and supplemental service rates apply to customers with their own generation who rely on the utility only intermittently. The design problem is that such a customer imposes capacity cost without contributing corresponding energy revenue, so the tariff typically combines a reservation charge for the capacity held available with an energy charge for what is actually taken.

      Time-varying and seasonal pricing

      The cost of serving a unit of consumption is not constant. It is higher during hours when expensive resources must run and when capacity is scarce, and lower when it is not. A flat energy charge averages that variation away, so the customer sees no signal about when to consume. Time-varying rates restore the signal by pricing periods differently.

      Designs range from a simple two-period schedule with a peak and an off-peak price, through three-period schedules adding a shoulder, to critical peak pricing that applies a much higher price on a limited number of days announced in advance. Seasonal differentials operate on the same logic across months rather than hours, charging more in the season when the system peaks.

      Two constraints shape adoption. The first is metering: a rate cannot be billed on a basis the meter does not record. The second is bill volatility, since a customer whose consumption is concentrated in high-priced hours will see an increase without any change in behavior. Commissions address the second through transitional periods, bill protection during a first year, and default-versus-optional decisions about who is placed on the rate.

      Whichever structure is chosen, it must still collect the class target established under allocating cost between customer classes, computed from the total assembled in the revenue requirement and how it is built. Charges that recover volatile purchased energy costs are usually handled separately through the mechanism described in fuel and purchased power adjustments rather than embedded in the base energy charge.

      Points to carry away

      • The customer charge recovers costs that do not vary with consumption, and its level determines how much of the class total is collected regardless of usage.
      • Energy charges may be flat or arranged in blocks that rise or fall with consumption.
      • Demand charges bill larger customers on measured maximum load, usually with a ratchet that carries a peak forward.
      • Federal law directs state commissions to consider standards including time-of-day, seasonal and interruptible rates.
      • Any design must collect the class revenue target, so raising one component requires lowering another.

      Questions readers ask

      What is a revenue-neutral rate design change?

      It is a change to the structure that leaves the class revenue target unchanged. Raising the customer charge and lowering the energy charge by an offsetting amount is the standard example. The class as a whole pays the same total, but individual customers do not: low-use customers pay more and high-use customers pay less. Revenue neutrality therefore describes the effect on the utility rather than on any customer, and describing such a change as costing customers nothing is inaccurate.

      Why do demand charges use a ratchet?

      Because capacity is built to serve a customer's maximum demand whether or not that maximum recurs each month. A ratchet bills the customer on the highest demand recorded within a preceding period, often eleven months, so that the charge reflects the capacity reserved rather than the capacity used in the current billing period. Customers object that a single unusual hour can set the charge for a year, and tariffs often soften the effect by billing a stated percentage of the historical maximum.

      How does an inclining block rate differ from a declining one?

      The price per unit rises with consumption under an inclining block and falls under a declining one. Declining blocks reflect the historical observation that serving an additional unit to an existing customer costs less than the average, since fixed costs are already recovered. Inclining blocks are adopted for conservation reasons and for distributional ones, since higher usage correlates with larger premises. The federal standard directs consideration of declining blocks specifically, requiring that the energy component not decrease with increased consumption unless cost justified.

      Sources

      1. 16 U.S.C. § 2621 — Consideration of certain ratemaking standards (Cornell LII)Lists the standards state commissions must consider, including declining block, time-of-day and seasonal rates.
      2. 16 U.S.C. § 824d — Rates and charges; schedules (Cornell LII)Requires just and reasonable rates and prohibits undue preference between customers or classes.
      3. Ohio Revised Code § 4909.18 — Application to establish or change rateRequires a schedule of proposed rates, classifications and charges as part of the filing.
      4. Ohio Revised Code § 4909.15 — Fixation of reasonable rateSupplies the standard the resulting schedule of charges must satisfy.
      5. NARUC — publications library, Electric Utility Cost Allocation ManualDescribes the cost classifications that rate components are designed to track.
      6. 18 C.F.R. § 35.13 — Filing of changes in rate schedules (Cornell LII)Requires the revenue data under present and proposed rates that a design change must be tested against.

      Pinnacle Law Review is a publication, not a law firm. This article states general rules and cites its sources; it is not advice about any particular case, and the law differs by state and changes over time.

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