By Hudson Sangree and Robert Mullin

SACRAMENTO, Calif. — CAISO market participants and companies that do business with Pacific Gas and Electric could end up paying a hefty price for the giant utility’s financial collapse.

Other CAISO members are worried that PG&E, which plans to file for bankruptcy on Jan. 29, could default on its payments to the ISO and the Western Energy Imbalance Market, leaving other members to foot the bill.

PG&E’s troubles also have fueled talk of a wide-ranging ripple effect, particularly regarding the renewable power generators from which the utility has contracted to buy billions of dollars worth of electricity.

CAISO has tried to relieve members’ concerns about a potential default, saying PG&E has enough collateral to cover its debts and future payments.

“The California ISO has received inquiries relating to the financial status of Pacific Gas and Electric Co. in light of recent media reports,” it said in a Jan. 11 market notice. “The ISO wants to assure market participants that PG&E has posted collateral with the ISO to cover its outstanding and upcoming obligations.”

But one market participant, a major player in the West, told RTO Insider it could end up paying hundreds of thousands of dollars a month to the ISO if PG&E defaults. The representative spoke only on the condition of the utility’s anonymity.

In response to an inquiry from RTO Insider, the ISO said it couldn’t reveal the amount or type of PG&E’s collateral, calling the information confidential. CAISO officials declined an interview request. “We have shared all we can on this subject,” an ISO spokeswoman wrote in an email.

PG&E did not respond to a request for comment.

Scott Miller, executive director of the Western Power Trading Forum (WPTF), said he thought there was little chance PG&E would default on its CAISO payments.

“When it comes to CAISO charges, you’ve got to be concerned,” Miller said. “But because it’s necessary for the grid to operate, and PG&E wants to emerge from bankruptcy as a going concern … I suspect that would be the last thing they wouldn’t pay.

“Defaulting on the CAISO charges could cause all sorts of financial shortfalls in CAISO, and that has reliability implications,” he added. “I just don’t think PG&E would not pay its CAISO charges.”

Miller served until 2017 as a senior market adviser in FERC’s Office of Energy Policy and Innovation where he worked on RTO credit reforms. He said RTOs and ISOs have assumed roles as financial clearinghouses, for which they’re not ideally suited.

It could cast some doubt on whether CAISO can adequately assess PG&E’s creditworthiness, he said.

PJM has been scrambling to strengthen its credit policies following the collapse of GreenHat Energy, whose default is expected to cost members more than $100 million.

“This is an area that’s problematic for RTOs,” Miller said. “They’re extending credit and taking risk. That’s not in their traditional wheelhouse. They’re not in as strong a position as a clearinghouse normally is for assessing credit risk.”

Ripple Effect

PG&E, California’s largest utility, has seen its fortunes fall since the catastrophic wildfires of 2017 and 2018, for which it has received much of the blame. That blame was based on state investigations in some cases, and circumstantial evidence mixed with public distrust in others.

The utility’s stock price plummeted from more than $70/share prior to the 2017 fires in Northern California’s prized wine country to slightly more than $6/share following November’s Camp Fire, the deadliest in state history. The roughly 90% collapse in PG&E’s stock price represented a $33 billion loss in market value.

The utility announced Jan. 14 it would file for bankruptcy by the end of the month because it was facing at least $30 billion in wildfire liability. At least 750 lawsuits have been filed against it on behalf of nearly 5,600 plaintiffs, it said. (See PG&E Files Bankruptcy, as CEO Steps Down.)

On Wednesday, S&P Global Ratings further downgraded PG&E’s credit rating from CC to D status, the lowest grade used by the major ratings firms. The downgrade was based on PG&E missing a $21.6 million interest payment on $800 million in senior notes.

“We do not expect the company to make this payment during the [30-day] grace period given the company’s announcement that it expects to file for bankruptcy protection and commence a reorganization under Chapter 11 of the U.S. Bankruptcy Code,” S&P said in a news release.

The fallout from PG&E’s bankruptcy announcement is already beginning to hit its renewable suppliers.

“PG&E is the biggest utility in the biggest market in the West. It’s not just the RTO activities that people are concerned about,” Miller said. “It’s the bilateral contracts they’ve got for resource adequacy — renewable contracts, storage contracts, things like that.”

One generator, the 550-MW Topaz Solar Farm owned by Berkshire Hathaway Energy, recently had its credit rating downgraded to junk status — the same as PG&E’s — because it had signed an exclusive 25-year power purchase agreement with the utility, and analysts said it might not get paid. (See PG&E’s Credit Woes Spread, Worrying CAISO Members.) Also downgraded was NextEra Energy’s 250-MW Genesis concentrating solar thermal plant, built in 2007. PG&E is its sole purchaser.

PG&E reported to FERC in its 2017 Form 1 filing that it had signed about $40 billion in PPAs covering 2019 to 2043, including agreements to buy approximately $34.5 billion in renewable energy such as wind and solar.

In 2017, PG&E generated about 53% of its 61,397 GWh in bundled retail sales according to a security filing, with purchases making up the remainder. PPAs represented $42 billion of the company’s $78.8 billion in contractual commitments as of the end of 2017.

Once in bankruptcy, PG&E could attempt to cancel or renegotiate these contracts. Analysts say generators with above-market contracts signed years ago will be most vulnerable to having their prices reduced.

Credit Suisse analysts estimate that PG&E could save $2.2 billion a year by renegotiating its renewable contracts to current market prices, The New York Times reported. The analysts said PG&E is paying Consolidated Edison solar plants an average of $197/MWh, almost eight times the $25 to $30/MWh new solar plants are charging.

Jan Smutny-Jones, CEO of the Independent Energy Producers Association, said in an interview that his organization will push PG&E to honor its commitments to generators.

IEP sent a letter to California’s political leaders Jan. 15 urging them “to seek immediate assurance from PG&E that its energy-supplier contracts will be affirmed and that generation interconnection deposits supporting new renewable energy projects will be protected and used to develop the transmission upgrades necessary to interconnect those projects.”

Evaluating Exposure

While CAISO has said little publicly about the potential effects of PG&E’s meltdown, conversations are going on behind the scenes as market participants try to sort out their exposure.

The market participant that spoke to RTO Insider on background, for example, said it had been struggling to determine how much collateral PG&E had posted with CAISO and whether other participants would be obligated to pay its share and for how long.

Another concern is the tens of millions of dollars in grid management charges (GMCs) that PG&E pays to CAISO each year, for which other members also could find themselves on the hook. In 2017, PG&E paid $51 million to CAISO in GMCs. Those grid fees fund the ISO’s fixed revenue requirement and any default must be covered by other participants.

Fallout from a PG&E default could spread to the Western EIM as well. Because the EIM falls under CAISO’s Tariff, EIM members have an obligation to cover defaults, similar to other CAISO members, in proportion to their market activity. Their voluntary day-to-day participation in the EIM, however, could allow them to reduce transactions to minimize exposure, and even ultimately withdraw from the market.

CAISO members whose assets are controlled by the ISO have no such recourse. They must cover a defaulter’s payments under the ISO’s tariff provisions once the defaulter has exhausted its collateral or “financial security.”

The ISO’s tariff provisions on creditworthiness require participants without unsecured credit to post collateral in the form of “an irrevocable and unconditional letter of credit issued by a bank or financial institution,” a prepayment to the ISO or a combination of the two. It remains unknown what kind of security PG&E posted.

CAISO requires financial security sufficient to cover a participant’s “estimated aggregate liability,” which represents all unpaid obligations plus five trading days, providing the ISO a cushion before the participant responds to a call for additional collateral within the required two business days. Posted collateral must be sufficient to cover other liabilities as well, such as a congestion revenue rights portfolio that has gone into the red.

In a situation where a market participant defaults on its payments to the ISO and has no collateral left, section 11:29:17 of the CAISO Tariff lays out a process by which the ISO can spread the costs to other members proportionally based on their market activity. Section 29.11 of the Tariff stipulates that those provisions also apply to EIM members.

Another potential consequence of PG&E’s bankruptcy: CAISO’s own financial position could be adversely affected.

In awarding the ISO an A+ credit rating in 2016, Fitch Ratings said one of the key factors it considered was the “solid credit profiles of California’s three largest investor-owned utilities.”

That was before S&P and Moody’s Investors Service stripped PG&E of its investment-grade credit status, downgrading it to “junk” because of its dire financial outlook from the fires and the fact that California politicians weren’t riding to its rescue, as some had expected.

S&P still gave CAISO an A+ credit rating as of Thursday. CAISO’s current annual debt service costs of $16.9 million are well below the 2006 peak of $80 million, and the 2009 construction of the ISO’s Folsom headquarters accounts for most of its $181 million (as of 2017) in long-term debt.

‘Out the Window’

State Assemblyman Chris Holden, chairman of the Utilities and Energy Committee, who co-authored last year’s Senate Bill 901 to aid PG&E, said he wasn’t inclined to do more right away.

SB 901 contained provisions allowing the state’s IOUs to issue long-term bonds, with approval of the California Public Utilities Commission, to cover costs of the 2017 fires. Holden had said he intended to offer legislation to make the bill’s provisions applicable to the Camp Fire and other 2018 fires. A PG&E bankruptcy wouldn’t be good for the state or its ratepayers, he said.

Holden recently backed away from that effort, telling the San Francisco Chronicle, “Our purpose was to keep PG&E from going into bankruptcy, but that’s out the window now. Now the courts are getting out in front.”