Fresh intel from state utility regulatory filings

You’ve probably heard about Nat Bullard’s massive decarbonization slide decks, filled with charts and insights into decarbonization drawn from climate and energy data. This time he's waded through piles of utility regulatory filings — countless PDFs that hint at the inner workings of utilities and large customers — to find clues about everything from gas plant costs to new large-load tariffs. In this episode, Shayle and Nat, cofounder of the climate tech market research firm Halcyon, cover topics like: How utilities — especially small ones — are handling eye-popping interconnection requests New tariff structures that utilities are developing for large-load customers like data centers Historical precedents for this level of change on the power grid, like the 2000s Enron bubble and the 1930s buildout of the West How factories and other large-load customers are battling against data centers for sites Shayle’s greatest fear about energy in the next few years: That electricity rates will rise dramatically unless we tackle large-load requests and the cost of new infrastructure What industries to bet on in a world of rising rates What filings reveal about the cost of new gas generation Resources: Catalyst: The US power demand surge: The electricity gauntlet has arrived Catalyst: Making DERs work for load growth Latitude Media: High costs, delays prompt withdrawal of five more Texas gas plants Latitude Media: In Georgia, stakeholders still can’t agree on data center load growth numbers Credits: Hosted by Shayle Kann. Produced and edited by Daniel Woldorff. Original music and engineering by Sean Marquand. Stephen Lacey is executive editor. Catalyst is brought to you by Anza, a solar and energy storage development and procurement platform helping clients make optimal decisions, saving significant time, money, and reducing risk. Subscribers instantly access pricing, product, and supplier data. Learn more at go.anzarenewables.com/latitude. Catalyst is brought to you by EnergyHub. EnergyHub helps utilities build next-generation virtual power plants that unlock reliable flexibility at every level of the grid. See how EnergyHub helps unlock the power of flexibility at scale, and deliver more value through cross-DER dispatch with their leading Edge DERMS platform by visiting energyhub.com. Catalyst is brought to you by Antenna Group, the public relations and strategic marketing agency of choice for climate and energy leaders. If you're a startup, investor, or global corporation that's looking to tell your climate story, demonstrate your impact, or accelerate your growth, Antenna Group's team of industry insiders is ready to help. Learn more at antennagroup.com.

Speaker names marked ? are inferred from speaking time and the show’s known hosts — they are not voice-verified.

• 0:02Speaker 00

  Latitude Media, covering the new frontiers of the energy transition.

• 0:07Shayle Kann?

  I'm Shil Khan and this is Catalyst.

• 0:11Speaker 02

  What tends to happen with a lot of this stuff is redaction for essentially the equivalent of trade secret reasons, and this is nothing new. But it tends to be very frustrating when you'll have pages and pages of text and then blacked out is the one number that says, "How much this gas plant is going to cost", right? Or the one thing that says, "The load for this data center is this", and it's been blanked out.

• 0:31Shayle Kann?

  Coming up, Nat Bullard and I dig for buried treasure inside the reams of documents coming out of state public utilities commissions.

• 0:48Speaker 00

  Demand flexibility is now an essential part of the data center's speed to power playbook. But how do data centers actually curtail load? GridBeyond is the end-to-end solution for flexible energy management. GridBeyond's advanced derms and VPP platform is tailored to what data centers care about most: maximizing reliability, intelligently meeting curtailment obligations, reducing costs, and managing all your distributed resources in one place. Ready to transform your distributed energy management? Get started at gridbeyond.com. Catalyst is brought to you by Antenna Group, the communications and marketing partner behind the most influential companies in energy, climate, and infrastructure. For three decades, Antenna has helped ambitious companies stand out, build market leadership,

• 1:31Speaker 00

  and become category-defining brands. From breakthrough startups to global industry leaders, their team brings the expertise, relationships, and track record to accelerate your momentum. Learn more at antenna group.com.

• 1:45Speaker 03

  The power plant for the modern grid isn't a building, it's a network. Energy Hub's derms platform connects batteries, EVs, thermostats, and commercial and industrial sites into virtual power plants that over 230 utilities dispatch as reliable grid capacity day in, day out. VPPs deploy in 60 to 100 days at 40% to 60% less cost than traditional infrastructure, and they perform like conventional generation from day one. Learn about the flexibility platform for the modern grid at energyhub.com.

• 2:21Shayle Kann?

  I'm Shao Khan. I invest in early-stage technologies at Energy Impact Partners. Welcome. All right, so some of you may already know this, but my first job, my very first job out of college was working at the California Public Utilities Commission, the state regulator for utilities in California. I had fallen in love with energy, for whatever reason, I've never quite been able to explain it all these years later, but I didn't really know what to do with myself, and I sort of found an in to the CPC. It wasn't a long time that I was there, and I learned, among other things, that I don't like working for bureaucratic organizations. But I will say that in my brief tenure there, I think I learned more about how the electricity and gas markets actually

• 3:03Shayle Kann?

  work than any other role that I've ever had since. And this was like, close to 20 years ago. It's just so important to understand the regulatory construct and the process that leads to regulation and ultimately to decisions in the electricity and the gas sector, which all is born out of these public utilities commissions. The other thing that's so interesting about them is that there is an enormous amount of information and insight and data that is in the public domain through these regulatory processes, but is buried in esoteric, long, hard-to-read PDFs that they post on their websites. So I've really enjoyed that my friend Nat Bullard, who you've heard for on this podcast many times,

• 3:46Shayle Kann?

  has started to chronicle some of the interesting findings that he's getting out of using LLMs to pull insight from public utility regulatory filings through a company he co-founded called Halcyon, which does this in general and builds all sorts of information tools out of these capabilities. Nat has started to publish a sort of regular update newsletter type of thing of interesting little tidbits from what's happening across the country in state utility commissions. So I decided to have Nat on to talk through some of the more interesting ones and give us a little flavor of what's happening at the state level right now as utilities wrangle with the multiple challenges they are facing, ranging from large loads...

• 4:32Shayle Kann?

  I.e. data centers entering their territories, trying to keep rates down for customers, trying to manage their other large customers who are increasingly irked by the preference given to the data centers, and so on. So Nat and I had a fun conversation about a bunch of these. Also, before we begin, I'm hosting another Ask Me Anything episode where I will answer your questions, large and small, about whatever you want. I think you know the types of things that we like to talk about here. If you want to ask a question, which I hope that you will, just email us at [email protected]. That's [email protected]. And for now, here's Nat. Nat, welcome back as always.

• 5:11Speaker 02

  Shale, thank you for having me back. It's great to be here as always.

• 5:15Shayle Kann?

  Let's do a little tour of state regulatory filings, state utility regulatory filings for fun tidbits. All right. So you picked out a bunch that you thought were particularly interesting, or I guess indicative of something that's happening in the moment. So I want to start in Pennsylvania. What's going on in Pennsylvania?

• 5:33Speaker 02

  So I remember a couple of years ago when I started having to think about how the court system works for purposes of jurisprudence in the United States. And I learned about this thing called en banc, E-N, space, B-A-N-C, which means that all of the members of a particular court, all the presiding judicial officers, get together and partake in a hearing or proceeding all at once. And as you can imagine, it doesn't usually happen that way. You usually have one judge do something, and then maybe you need to get others to help, you know, concur with an opinion or whatever. But it's not something that I'd actually heard about much in a judicial context. And now I start to hear about it in the Public

• 6:13Speaker 02

  Utility Commission context in Pennsylvania. And this has come up in Pennsylvania where there's this en banc hearing about large load interconnection, read, data centers. And this is the first time that I'd ever seen one of these things, to the point where I had to ask a friend of ours and an advisor, does this happen very often? To which the response is, no, like, this almost never happens that you get everybody together at once. And in fact, typically, that would only happen- For something like restructuring a generation fleet or getting to set new retail markets like some big kind of market and state defining thing that would be happening in any particular market.

• 6:56Speaker 02

  So getting everybody together like this is pretty interesting because obviously it's a kind of an accelerated way to make sure that everybody's bought in on a decision. But it also tends to bring all the players to the yard too. This is going to bring all of the different interveners, all of the different expert testimonies and things like that all together into one place. And one of the things that you're finding in this process in Pennsylvania is first of all, not surprisingly, there's just a ton of data center operators and also the data center coalition, which is the sort of, you know, group that works on their behalf, coming together to make an argument, but so too are all of the utilities. And they start putting together some eye popping numbers in terms of exactly what's going on in the state.

• 7:39Speaker 02

  So one of my particular favorites was from Duquesne Light, which has a relatively small service territory. And they said that there are four projects in advanced stages of connection essentially in their service territory that could add forty percent to their demand. And one really big hyperscale thing could add thirty percent to their demand on its own. So this is, there's a reason why this is an en banc proceeding because we're now at a place that we probably haven't seen since the US was being electrified full stop. Where people are showing up and saying, hello, I have one thing that will materially change the shape of load and demand pretty much forever.

• 8:23Shayle Kann?

  Yeah, it's wild. And we're seeing that sort of all over the place, like not literally everywhere. It is still true that data center development is somewhat clustered, but less and less clustered, it seems as time goes on. And the scale of these things are so big and some of these markets are so small that they're just swamping utility territories. There's another one that's like a

• 8:46Shayle Kann?

  Rappahannock Co-op or something like that. I'm butchering it, but there's, do you know the one that I'm talking about?

• 8:50Speaker 02

  One of my favorites, the Rappahannock Electric Cooperative. I know it very well because it serves the territory adjacent to where my folks had their farm in Virginia. Yeah.

• 9:00Shayle Kann?

  Okay.

• 9:00Speaker 02

  And they said, they're like, we had-

• 9:02Shayle Kann?

  Yeah, there are another one where it's like 200% of their peak load or something like that.

• 9:05Speaker 02

  More than, more than that, Shale. So they said, hi, we have a 1.2 gigawatt summer peak load. We have individual interconnection requests that are four times that size. And so they're basically, they're saying, A, we need to do something different physically in the physical grid to do that. But B, we also need to come up with a different regulatory construct in which to do it. In, in sort of in two dimensions. One of them is, how are we going to, you know, how are we going to get this paid for if it's done? Because basically you're building on behalf of a handful of customers as opposed to, I don't know, 100,000

• 9:47Speaker 02

  customers in the service territory. B, how are they going to pay, how are we going to make sure that they pay for it? And the other one is, what if they don't show up? What if we build for them and then they don't actually materialize? You know, which is the, I think that could normally happen in normal grids is that you plan for demand that never materializes. And then what? If they plan for the kind of demand that wouldn't materialize until the year 2250 without, without data center mode, who's going to be paying for it?

• 10:15Shayle Kann?

  I was thinking about, like, so this is happening all over the place. And in fact, I think on our list of things to talk about, there are more large load interconnection dockets to talk about because this is sort of like, one of the bigger things that's happening all over the place. And, and it is, as you said, there's a lot of nuance to it that has to be figured out in each individual case. There are these questions of how you structure the tariff in the first place, how you ensure cost allocation is done right. Are you demanding some sort of flexibility or bring your own generation or bring your own storage or whatever it might be? How, how does the asset interact with the grid? Is there demand response? I mean, there's like a million things to figure out. But it's interesting, the fact that this is happening- In so many places, kind of all at once.

• 10:58Shayle Kann?

  And at least in some of the places, the magnitude of the impact that it will have on the overall system, I was trying to think back on the last time that some that this sort of level of change was afoot in electricity in that quick a timeframe. And I wonder whether we could make one argument, it was like when we were doing our natural gas build out in the country, but I that felt like it was over the course of a decade or something like that. I don't know, maybe it wasn't quite as dramatic. But maybe it was deregulation. It was like the period when, what is it 14 states or 17 states, something like that deregulated over the course of a few years and then Enron like put a, put a stop to the rest of it.

• 11:40Shayle Kann?

  But that feels like the last time I can think of where we had this like total transformation of a, a large market, but occurring at a state level because of how everything is now because of the states or the jurisdiction that matter here.

• 11:55Speaker 02

  So it's, yes, at the state level, you had deregulation and you had the Enrons at a phenomenon. You had this massive boom in combined cycle gas turbine build that crested in the early 2000s and then burst, like went away for, for quite some time. We know in terms of load growth in a percent basis, you know, in the 1950s, it was close to 10% per, per annum. But I would posit that in terms of thinking about the, the full physical and regulatory construct of the grid, you'd probably have to go back to more like the 1930s and think about building in the far west, building at the same time,

• 12:36Speaker 02

  a massive amount of generation built by the state, to be clear, with transmission owned by the government, to be clear. And then with at the same time, loads that came along. You know, sort of coincident with that for things like smelters. The kind of things that when they eventually departed field, ended up creating the capacity or the generation capacity in the grid spare to allow data centers to get built in the first place. So I, I think it's been a very long time. I don't think that really anyone has got the muscle for this because it's not been in anybody's lived experience, really. And so we're having to think about it pretty fresh. There are people that have dealt with rapid growth.

• 13:20Speaker 02

  There are people that have dealt with deregulation. There are people that have dealt with large load customers. But all of these things at once, and also a new type of large load customer that has different characteristics than what you might've had before, is quite a lot to deal with in one go.

• 13:36Shayle Kann?

  Not to mention, as you said, the risk that some of it isn't going to happen. I mean, the certainty.

• 13:42Speaker 02

  That's right.

• 13:42Shayle Kann?

  Sorry, the certainty that some of it is not going to happen, right? But how much and which ones?

• 13:45Speaker 02

  This is a development business.

• 13:46Shayle Kann?

  Yeah.

• 13:47Speaker 02

  This is a development business fundamentally. And I think it's something that has been elided from the conversation in a lot of cases. You know, if this was, if we were talking about purely a supply push, like we were doing just generation without the demand there. Anybody who's ever been in the power generation business is going to tell you, obviously, not all of these things are going to show up. But the demand side has not typically been pulled into that kind of conversation before and asked the same questions. Are you going to build every single planned prospective hyperscale data center that you have on paper right now? The answer is no.

• 14:24Shayle Kann?

  And how long are you going to operate it for, right? We're building infrastructure that assumes that that tariff we're giving you is going to be getting paid for, I don't know, decade, two decades, whatever it might be.

• 14:35Speaker 02

  That's right.

• 14:35Shayle Kann?

  And this stuff could change quickly. All right, let's jump to another one in this category. I'm going to jump to number three on the list that you sent me because it's relevant to the point that you just made about the 1930s where we're building out manufacturing infrastructure too. So one of the interesting side effects, sort of, of this, this data center boom in electricity is that it does affect the other existing large load customers who do exist, albeit not in the numbers and not with the growth that we see in data centers. So let's talk about Kentucky.

• 15:07Speaker 02

  And let's talk about specifically Eastern Kentucky. The East Kentucky Power Cooperative, again, to be fair, not really on my radar in my previous life, you know, covering electricity demand growth, has set out to do its own, again, essentially custom data, the data center large load tariff. And it's now working its way through the state utility commission discussions. At which point, Nucor enters the chat. Nucor, the mini mill steel producer, which obviously uses an almost entirely electrified process for its energy input, has said, hey, we're the biggest load in Eastern Kentucky, and we have been for a long time.

• 15:51Speaker 02

  And we want to be very clear that we are an intervenor and read in on this process because it impacts us. And also, sort of implicit in that, kind of to what we were just talking about, is we've been around for a while, and we're going to be around for a while. We're not new. We operate under existing structures. We would like to be kept abreast of what's happening here, to put it very gently. But more importantly, it serves as a reminder that there are other large modes that are out there. In fact, there's another one in the region, which is the Blue Oval Plant, being built by Ford and SK on to do batteries. That's like a couple hundred megawatt load on its own.

• 16:31Speaker 02

  It's not a five gigawatt, you know, prospective hyperscale data center complex, but it's very big. And it's the kind of thing that typically has relied upon the grid writ large to provide most of its power. And so if you're going to have large load tariffs that come into these kinds of market structures, everybody else that either needs one of those themselves now, or might need one in the future, or has been a beneficiary of a well-functioning grid to begin with, is going to kind of want to be read in on this process. It's really, it's important to see, and I think, I said this sincerely, to see incumbency sort of jump into these discussions as well, in some ways as a reminder that there is still a lot of other stuff out there that's happening.

• 17:15Speaker 02

  But also that, you know, we should be judicious in our thinking about everyone getting their own custom new large load tariff, and what that's going to mean.

• 17:24Shayle Kann?

  Yeah, and I think it speaks to one of the adverse side effects of the AI boom that I think goes Under discussed, which is that if you believe that there are limited resources specifically in the form of large load interconnection capacity, which there are limited resources in large load interconnection capacity, then anything that is not a data center is currently battling against data centers to try to find a site. And that's an issue if we want to re-industrialize the United States, right? Like, all this new manufacturing that we hope to build in the United States, those are large loads. Those need tens or hundreds of megawatts at an individual site. And I can tell you for certain that it is getting

• 18:09Shayle Kann?

  harder and harder to find a site to put any of that stuff because there are data center developers hunting around the entire country trying to find anywhere where that is possible. So it's making it, and that's difficult for manufacturing, for, you know, industrial electrification of whatever stripe. I mean, even down to the scale of like fleet EV charging for medium and heavy duty vehicles. Like, it's a challenge that is being presented specifically by the growth of data centers.

• 18:39Speaker 02

  And not only that, it's a particular class of customer which, and I think we talked about this in our yearly pod, in our yearly DAC podcast earlier this year, that is almost uniquely underexposed economically to the cost of electricity relative to the gain to be had from its access. If you jack the price of electricity 30% for somebody that makes steel using an electric arc furnace, it will materially impact the cost of the steel that is being made. If you do the same for people that are doing data center operations, especially for training where the premium is on being fast, it's just not going to be as big of a deal. You've got a unique willingness to pay from one class of customer, too.

• 19:22Shayle Kann?

  Now, this is a question that I have, which I don't know if you can or have pulled out from this data, though, which is, we talk about that in principle. Is it happening in practice? In other words, are these large load tariffs that are being introduced at a premium to other industrial rates in the same territory? Like, are utilities and our regulators getting on board with, and are large loads, are your data centers being, saying okay to the concept that they will actually pay more?

• 19:52Speaker 02

  So there we're in the realm of redaction to some extent, but also a lot of these are very early. They're mostly under deliberation right now, and we don't have a lot of clarity on that. But it's something we need to get clarity on. And within that, what are the exact conditions of it? Is it an adder to an existing rate? Is it a newly agreed flat rate? Does it escalate? You know, what's its duration? All of these things are deeply relevant. And, you know, the fascinating thing about all of them is that for as much as this is like crunchy and quantitative outcome, it's just going to be like a line in a, you know, it's going to be like a line in a document somewhere that just says what it is.

• 20:31Speaker 00

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• 21:13Speaker 00

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• 22:41Shayle Kann?

  All right, well, that's a good segue into something that is not directly about large load interconnection tariffs, but I would say is the fear everyone is trying to avoid with all these new large loads. And stepping back is the greatest fear that I have about energy, honestly, for the next few years, which is that electricity rates are going to be rising. They have been rising more than historically. I mean, I live in California where they've been rising like crazy, but even outside of California, right? They have been rising. I worry they're going to rise a lot more if we don't get this large load interconnection thing right, but also for a variety of other reasons, right? We'll talk more, I think, a little bit later about the cost of new gas build, where we have a bill that is making its way through Congress right now that's going to affect

• 23:26Shayle Kann?

  the cost of renewables. Like, there's a lot of inflationary trends in that, and that poses a bunch of challenges. So you pulled some interesting data on rate increases. Again, this is not rate increases for large loads necessarily. This is more retail rates. But talk to me about Vermont, Mississippi.

• 23:43Speaker 02

  So I deliberately cast my eye into some of the smaller utilities, service territories, things like that. And to be clear, actually, not just electricity, but also gas and water, because these small places get less sunlight on them, they almost definitionally serve a smaller group of customers.

• 24:06Speaker 02

  Many cases who were of a particular, a particular kind of economic alignment like they, you know, if it's a small town in the middle, in the middle of the country, they probably have fewer very large load, you know, rate payers. They might be almost entirely residential. And three, their reset cycle on this stuff probably isn't that frequent. Some of these places don't do a rate reset for a decade, which if you think back to rates that you might have set at a period of zero growth and essentially zero interest rates, and now jumping forward 10 years to do a reset, you've got a nonlinear gap up that happens. So Vermont, yeah, everybody's favorite utility, the Village of Ludno Electric Light Department,

• 24:49Speaker 02

  you know, requested a 21 and a half percent rate increase effective July 1. And this, by the way, was something that was proposed a couple of weeks ago, basically. You know, not a California-style process that's going to go on for three years and get covered in the newspaper and get picked up by a lot of different interveners and advocates and whatnot. Uh-uh. You know, the Village of Ludno Electric Light Department says, "I need 21 and a half percent increase now," basically. And, you know, the pushback from the Department of Public Services is basically saying, "No, like, we need to set a conference to actually discuss this. You can't just go and do that." And that's one of many of these things that keep coming up.

• 25:31Speaker 02

  You know, we see this all over the place in some of these smaller service territories. And we should remember that these are inherently regressive. The impact of rates inherently hit people on fixed incomes and lower incomes higher. So you can imagine, especially if we have these changes that are happening with the bill in Congress, if you imagine this sort of writ large across many, many different places all at once, it's going to be a bit of a mess. I'll give you, this other one you mentioned, Mississippi, the Great River Utility Operating Company, in this case, it's doing, it's talking about its gas rates, has basically said that they're going to go and scrub what has been a kind of tiered sewer, sorry, not gas, but sewer rate. And they're just going to scrub it from three different tiers into one.

• 26:17Speaker 02

  Which again is going to massively impact the people that are on the lowest tier of rates. Uh, that is now jumping up to one fixed higher tier with almost like no deliberation and and no discussion. They've gone to in quote immediate eliminate all rate tiers mitigated rates and residential metered rates in favor of one statewide residential flat rate for water and sewer services. Ouch. Like, like, that's a big deal for the people that had been used to a residential mitigated rate that would have been a third maybe of what the new rate might end up being.

• 26:52Shayle Kann?

  Do you worry as I do about retail electricity prices? I guess too, I guess. But I think more about electricity. Do you worry about how much retail electricity prices are going to rise in the next five to 10 years?

• 27:04Speaker 02

  I do because we've, we've, we've made it very difficult. Uh, rather, we've taken away a lot of the instruments that were meant to help suppress those rates by sort of distributing the cost across federal government expenditures and tax, you know, tax rebates and whatnot in favor of uh, nothing that really helps support fast moving new generation. But also we have labor shortages. We have still a fairly pro inflationary environment for, for a lot of different things going in. We have the challenges of the cost of infrastructure itself. Transformers are not getting any cheaper anytime soon. So I am concerned about this. And I'm also concerned that the kind of mechanisms that we're familiar from early

• 27:48Speaker 02

  in our career that can respond to that, namely build a bunch of cheap distributed renewable generation right now, uh, are, are impaired to some extent by current legislation. Maybe, maybe the, maybe we will find just how flexible and fast and low cost some of these renewable generation elements can be to get to market very, very quickly. But that does nothing for the cost of wires. It does nothing for the cost of transformers. Uh, it does nothing for the cost of labor necessarily. So I am concerned about, about that. And again, it's a, these are sort of muscles that we haven't had to really, uh, exercise in quite some time in the U.S.

• 28:30Shayle Kann?

  I was having a conversation recently with one of my colleagues about this and at the IP and, you know, I was saying, okay, like my, my conviction is growing stronger and stronger that rates are going to be somewhat inflationary broadly across the board for, for a while. So then I thought, okay, my, I'm a venture investor, like, what should I be betting on that is effectively a bet on, on rising rates, distributed energy resources being one sort of obvious potential category there. The other one that he pointed out that like should be obvious, but wasn't to me for reasons that you will appreciate was, is energy efficiency, which is a category that has just ended up very unloved in sort of tech and venture circles. And, and you're a student of clean tech 1.0 as I am and

• 29:14Shayle Kann?

  the history of this sector. Do you have any like lessons you've taken away from hottest scale energy efficiency businesses or technology? Cause it feels like this is a moment when efficiency should be the thing, but you just don't see that much of it in terms of like true new innovation happening.

• 29:33Speaker 02

  No, I mean, like, if, if I think back to one of the 1.0 examples, you could show people material savings on their bill by implementing behavioral responses, by doing something to help them with more efficient devices. And it just didn't seem, it somehow didn't seem to impress people in the same way that offsetting all of their demand through, you know, a home PPA might have, whether or not the economics of it fundamentally were like a good, a good idea for somebody or not. People always wanted, they wanted something more. And I, and I think that there's a psychology of I'm doing less or I'm getting

• 30:13Speaker 02

  less is probably a challenge. You know, I would welcome another set of approaches, but is behavior going to be enough to do that? I don't know. Is it, you know, is, is yet another kind of behavioral approach to saving money going to work? Is it going to be about shifting load around in the house? I mean, back in the day, it was, you'd better run your washing machine at night because that's when the rates are lowest. Now is it going to be something else? Is it something you could automate? Away or you know what one aspect is is this something that we've already kind of internalized by just getting a Nest thermostat already and people just don't think about it. You know, like, what are the what are the equivalent things like that, though? Where you could make money.

• 30:54Speaker 02

  Certainly, Nest was a handsome exit for its venture investors. But how many of those are we going to find? And how many of those are are applicable across a much bigger, broader market? I don't really know.

• 31:07Shayle Kann?

  Right. Okay, let's back to your list of interesting tidbits from regulatory filings. You did some clever sleuthing to find some cost data on natural gas on on what combined cycle turbines, which is a topic of much discussion these days. In part, I think, in particular spurred by the CEO of Nextera, who has been, I think, in the context of advocating for continued tax credits for solar and wind and just support for solar and wind and storage, saying like, you know, we're going to build lots of new natural gas in the United States, new gas generating capacity, I should say. But it's worth noting, not only is the timeline elongated by the turbine shortage, but also the costs have gone up a lot.

• 31:50Shayle Kann?

  And he cited some numbers that are that are sort of anecdotal. So I think more data that that supports or doesn't support the how much is it going to cost to actually build these plants is is pretty valuable because it speaks to alternatives, but it also speaks to what we were talking about before, like where rates going to go. So anyway, what'd you learn?

• 32:09Speaker 02

  So, yeah, I actually really appreciated the Nextera CEO's comments, which were at CERA Week, where he said, you know, it's going to be about $2,400 a kilowatt to build a new gas plant. And that number has essentially become gospel to the point that it is picked up from third parties now, like that that according to so and so was something, a number that originated from a talk on the stage. And to an extent, it was kind of the inspiration for the work that we did to say, well, can we demystify that a little bit? Like, I, you know, as an old analyst, I'm as fond of anecdotal data as the next guy. But I think it's important to put some some reality to it. So, you know, we did it. We did a sort of canvas across everything we could find.

• 32:50Speaker 02

  Across all 50 US states, we've got about 55 gigawatts of plants and like more than 100 individual plants and way more than that number of different generators. And what we see is that actually his number is not bad. $2,400 a kilowatt, what we see by 2031, 2032 is about $2,230 to $2,240 a kilowatt. And legitimately double what it was just a couple of years ago. And this is also a case where, where, you know, the, the kind of, the, the gold standard here is the EIA's cost of generation publication that it does every couple of years. And they published this just in 2024 and the benchmark price and after, after engineers had looked through it,

• 33:33Speaker 02

  was somewhere in the range of about $1,100 to $1,200 a kilowatt for a combined cycle plant. And that's just a conclusion not found in evidence. If you look into what's actually there and what's happening. So, yeah, I will say to the next era CEO's credit, his number is pretty good in terms of describing reality. But the important thing too is to just keep a change log on all of this. How are those prices going to move? Are new, as new assets enter, where are they going to be priced? How are the timelines on which these things are being built going to change? How much is the cost of construction going to change? And that's all the kind of information that, that in an ideal world would be disclosed through some kind of

• 34:15Speaker 02

  project update documentation that's made public, but it definitely is not. It's the kind of thing that comes in, you know, financial responses to requests for information and things like that. All nested within particular proceedings in particular states. But in aggregate, you know, an important story to get, to get wrapped up and told clearly.

• 34:35Shayle Kann?

  All right, I want to wrap with a random tariff that you found in South Dakota. For a startup that, you know, does interesting things in climate tech that we've talked about the category before, but talking about South Dakota.

• 34:49Speaker 02

  So, South Dakota, not a particularly big service territory.

• 34:54Speaker 02

  It has a major utility there called Otter Tail. Tremaine's one of my favorite names. Animal-themed power utilities up there with Bear Valley Electric in California. And it has designed a sort of one-of-one tariff for Antora. So Antora received a state grant along with another large, sort of large-energy user or large-energy player, a "international cheesemaker" in April. And ongoing now is this discussion for this sort of one-of-one tariff that is "deviating from standard rate schedules and it's applicable, basically, only to Antora."

• 35:36Speaker 02

  So we're watching it proceed through the process without, at the moment, like a great deal of detail. A lot of it is still being sort of covered up by the nature of the process, but we'll find out later on. But it is a fascinating case. You don't have to be the world's biggest company to get a custom tariff, but you might also have to be operating in a small-service territory, relatively speaking, to be able to do it. And again, what I find so interesting about all this stuff is that they're not really, to my mind, at the level of trade secret, but they are at the level of comparative advantage. But at the same time, there's elementation of all of this decision-making process and the result that's in the public sphere if you know where to go and get it. You know, I joke about this with somebody, they're like, "How much stuff are you looking at?"

• 36:20Speaker 02

  I was like, "Well, it's like a denial-of-service attack, basically, through public disclosure. We'll give you everything you want, as long as you don't mind reading a landscape-printed PDF of an Excel file that has been turned into 1,500 JPEGs and uploaded in one go." But back to the Antora thing, it's neat, it's a good thing to be watching, it's probably the first of its kind there in the state, but then the question will be like, "How can we learn from this and everybody get more efficient at doing things like this faster and ideally cheaper and better as we look across all the different markets everywhere?"

• 37:00Shayle Kann?

  All right, Nat, this was fun, as always. Keep hunting.

• 37:03Speaker 02

  I will.

• 37:03Shayle Kann?

  Those regulatory dockets. We'll find some more tidbits and talk about it again.

• 37:07Speaker 02

  Awesome. Thank you, Shayle. Always a pleasure.

• 37:11Shayle Kann?

  Nat Bullard is the co-founder of Halcyon. This show is a production of Latitude Media. You can head over to latitudemedia.com for links to today's topics. Latitude is supported by Prelude Ventures. This episode was produced by Daniel Waldorf. Mixing and theme song by Sean Marquand. Stephen Lacey is our executive editor. I'm Shayle Khan, and this is Catalyst.