Op-Ed: Evaluating P.R.’s energy transformation is an opportunity to define, promote public interest
Puerto Rico is overhauling its electrical power system: evaluating its integrated resource plan (IRP), approving wheeling regulations, acquiring a concessionaire for transmission and distribution, and setting up private management of power generation plants, among other measures that will affect the island’s electrical system for years to come.
Unfortunately, a scattershot
approach is being taken to address the complexities of restructuring the energy
sector. It has become a battle of ideologies, private vs. public ownership,
fighting over which side offers more promising performance. The policy
proposals have become driven by ideological preferences rather than concrete
The travails of the Puerto Rico
Electric Power Authority (PREPA), like PG&E in California, have
demonstrated that it is not the type of ownership, private vs. public, that can
bankrupt a utility. Rather, it is a lack of accountability and protection of
the public interest.
I had the privilege of serving
from 2014 until 2018 as associate commissioner and later, as chair of the
Puerto Rico Energy Commission, now called the PR Energy Bureau (PREB). During
my tenure, when asked by a reporter if Puerto Rico could be held up as a model
for the rest of the world, my answer was that it would be more appropriate to
consider us “a model of what not to do” if we continued along the same course.
That course has not changed.
A multitude of stakeholders and
critics have pointed out the many flaws contained in the IRP.
However, there is one major
flaw from which all others emanate. Namely, there is a lack of definition of
what constitutes the public interest. The relevant statute states that any
changes must serve and protect the public interest. However, it does not define
what the public interest is. The PREB has not defined it either. As a result of
this lack of clarity, PREPA has framed the path forward through the lens of its
own perceived advantage – promoting natural gas over renewable energy.
It is important to point out
that PREPA’s interests are not the same as the public interest, the Authority
should be considered a private/special interest even though it is a publicly‑owned
Why is framing so important? It
is imperative that frames are understood to not become trapped by them. As linguist George Lakoff explains, “frames … shape the goals
we seek, the plans we make, the way we act, and what counts as a good or bad
outcome of our actions.” Once a frame is set, it may be accepted as the norm by
PREPA has controlled the
framing of the IRP by repeatedly using phrases and terms such as: “hybrid
decentralized system,” “customer-centric,” “wind energy production occurs
simultaneously with solar photovoltaic (PV),” “offshore wind will take too much
time to study and develop,” “electric vehicles are not practical in PR,” “we
have evaluated multiple scenarios,” and “PV and storage will not produce power
as quickly as a mobile gas unit after an event like Hurricane María,” just to
name a few recurring messages.
PREPA’s proposal bucks decentralization
However, if asked to define what a decentralized system is, the answer
would not be anything resembling what PREPA is proposing. PREPA’s version is a
system with big centralized natural gas plants, and a transmission and
distribution grid divided into eight regions that PREPA calls “mini-grids.”
A truly decentralized system
would rely instead on small generators, in this case solar generators,
dispersed throughout Puerto Rico. Simply calling a system “decentralized”
does not make it so.
PREPA has also proposed the
mini-grids as boosting “resiliency” but for critical loads only (loads related
to safety and health). There is no mention of the fact that after the
devastation of Hurricane María, most, if not all, the critical loads on the island
now have some form of back-up power, either solar with storage or a backup
generator. So, it is unclear what additional value these new “mini-grids”
PREPA also claims it has
received anecdotal evidence of solar systems failing during the hurricane. Such
statements frame solar as incapable of providing resiliency. In reality, it
ignores the fact that, before Hurricane María, solar systems were installed
primarily for bill reduction purposes (net metering) with technologies that
only work when the electric grid is up and running. The framing ignores that
current installations can have energy storage and the appropriate technology
for off-grid operation.
During its evaluation process,
PREPA claims to have examined multiple scenarios. It is true that PREPA looked
at several variables, however, in reality, the ones tested can be boiled down
to just two options: the status quo and adding natural gas-fired central
plants. The “variety” of scenarios merely changed the locations for situating
the central gas plants.
Renewable energy has been
severely short-changed during the evaluation process. Fundamentally, a system
driven by renewable energy was never seriously taken under consideration. It is
only viewed as a supplement to natural gas. Second, only utility-scale solar is
evaluated. Individual and business investments in solar panels were brushed off
and offshore wind was completely ignored. In addition, the potential for
introducing electric vehicles was evaluated by only one “expert” who concluded
EVs would not take off in PR.
PREPA has been able to frame
and dominate the narrative of the energy transformation. Although not unique to
Puerto Rico, such framing happens in many other places, but it is extremely
alarming and dispiriting when, as nations move increasingly toward renewable
energy, opting for 21st century solutions, Puerto Rico’s answer is a 20th
century centralized fossil fuel-based system. Wouldn’t it be in the public
interest to attempt a different framing?
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