Synapse assisted the Ohio Office of Consumer Counsel with issues related to EPA’s Clean Power Plan. This work included providing consultation and analysis on the plan’s costs to Ohio consumers, allowance trading, energy efficiency as a compliance option, and the impacts of compliance pathways on bills and emissions.
States ramping up their Clean Power Plan compliance planning face a dizzying array of tools available to support their modeling. Synapse Energy Economics and Argonne National Lab examined the modeling choices available to policymakers, energy planners, and stakeholders for the Clean Power Plan and other applications. Together, they produced a report entitled, the Guide to Clean Power Plan Modeling Tools, and an accompanying webinar to delve into the different types of modeling approaches that could be, and are, being used by states and stakeholders to assess compliance plans. In developing these resources, Synapse and ANL considered a number of factors—including EPA reporting requirements, the need for transparency, flexibility, analytic rigor, and geographic specificity—that will be important to successful compliance plans and their implementation. These same considerations are also important for integrated resource planning and other electricity modeling applications.
Guide to Electric Sector Modeling Tools - webinar slides
How will the U.S. Environmental Protection Agency’s new rule on carbon emissions from power plants impact the broader public? Synapse takes on this issue in a webinar designed for health, environmental justice, and other consumer advocates who now find themselves with a critical role in the stakeholder process as states make choices about Clean Power Plan compliance.
Based on Synapse’s in-depth analysis of emissions, costs to consumers, and energy options, this webinar provides an overview of the compliance planning process, particularly as it relates to stakeholder engagement and threats to community health. Panelists Elizabeth A. Stanton, PhD, and Pat Knight also delve into issues that have caused confusion since the rule’s release. These include the role of energy efficiency, allowance trading and pollution hotspots, who gets the value from trading, and dispelling myths related to rate vs. mass.
How is this webinar different from previous Clean Power Plan webinars Synapse has hosted? We focus on what health, environmental justice, and other consumer advocates can do to get the best outcomes for the communities they represent. Please share this link with anyone within your network that you think would be interested in learning more about how to participate in the decision-making process.
Fairness, Health, and the Clean Power Plan - February 2, 2016
Vermont Department of Public Service retained Synapse for this special project to address New England stakeholder issues regarding the electric grid and related topics. Synapse researched, analyzed, and provided recommendations on numerous topics. Synapse also provided advocacy on behalf of VT DPS in the stakeholder process.
Synapse provided analysis and expert testimony on behalf of Sierra Club in Oklahoma Gas & Electric’s application before the Oklahoma Corporation Commission seeking approval to install dry scrubbers at the Sooner generating facility. Synapse’s Tyler Comings evaluated the economic case for the retrofits with a focus on the assumptions used for natural gas price risk and fuel diversity. Mr. Coming’s testimony found that installing dry scrubbers at Sooner is not the least cost option. Mr. Comings recommended that the Commission deny the proposal. Should the Committee accept the proposal, Mr. Comings recommended it do so with conditions that would protect ratepayers.
Earlier testimonies from the Oklahoma Gas & Electric CPCN Proceedings can be found here.
Responsive Testimony of Tyler Comings on Oklahoma Gas and Electric Application for Approval to Install Dry Scrubbers at the Sooner Generating Facility
Synapse conducted a second supplementary audit of the operation of the Nova Scotia Power Inc. load retention tariff mechanism for Port Hawkesbury Paper pursuant to the Nova Scotia Utility and Review Board Decision Letter of May 23, 2014 in Docket M05803.
Riverkeeper retained Synapse to assess the potential impacts to energy reliability and electric power sector air emissions associated with the construction and operation of a closed-cycle cooling system as the "best technology available" (BTA) for the Indian Point nuclear power plant, in order to inform the analysis being conducted by the New York State Department of Environmental Conservation (NYSDEC) under the New York State Environmental Quality Review Act (SEQRA). Synapse found that the retirement of the Indian Point nuclear facility would result in essentially no reliability impacts and minimal air emission impacts.
Direct Testimony of Bob Fagan Regarding Air Emissions and Electric System Reliability Impacts of Closed-Cycle Cooling
Rebuttal Testimony of Bob Fagan Regarding Air Emissions and Electric System Reliability Impacts of Closed-Cycle Cooling
Surrebuttal Testimony of Bob Fagan Regarding Air Emissions and Electric System Reliability Impacts of Closed-Cycle Cooling
Synapse reviewed the modeling methodology used by Portland General Electric (PGE) in the development of its 2016 Draft Integrated Resource Plan. Synapse found that PGE’s methodology lacked rigor and, as such, did not sufficiently justify its portfolio selection for the draft IRP. In comments submitted on behalf of Sierra Club during a stakeholder feedback process, Synapse recommended that PGE address the flaws in the selection process by (1) conducting optimization modeling, (2) performing a probabilistic analysis, (3) replacing its unreliable metrics with standard measures, (4) providing scenario results to stakeholders, and (5) involving stakeholders in future procurement decisions.
Comments to Oregon PUC on PGE 2016 Integrated Resource Plan
One of the key benefits most attributed to energy efficiency and renewable energy (clean energy resources) is that they reduce the use of fossil fuel resources consumed for generating electricity, and in doing so reduce fossil fuel-related carbon dioxide emissions. Synapse reviewed a range of sources and compiled evidence that clean energy resources have indeed displaced generation by fossil resources connected to the grid, and that they are projected to continue doing so in the future. The report includes:
- utility-level case studies of electric system integrated resource planning (IRP) model results;
- a review of national-level analyses;
- an overview of marginal resources in different regional transmission organization (RTO) areas;
- modeling case studies using EPA’s AVERT; and
- a review of historical data demonstrating the impact that energy efficiency and renewable energy have already had on fossil fuel use.
In addition, the report highlights original Synapse analysis using the ReEDS model on the impacts of expanding clean energy resources on emissions related to fossil-fuel generation.
The Massachusetts Department of Energy Resources (DOER) commissioned a study to analyze how a possible revenue-neutral carbon tax (or fee) could be implemented in the Commonwealth. To explore the implications of a state-specific carbon tax, Synapse and Regional Economic Models, Inc. (REMI) developed a methodology for incorporating the supply-side energy system effects of CO2 pricing in the REMI macroeconomic models of the United States. Synapse used the ReEDS model to explore emissions and cost impacts of several policy structures for Massachusetts as well as for the rest of New England and the rest of the RGGI states.
Since 2005, Synapse has provided analysis of New Jersey's Basic Generation Service (BGS) procurement options for the New Jersey Division of Rate Counsel. The BGS procurement process includes annual auctions held by the State of New Jersey for the procurement of fixed-price, basic electric generation service (BGS-FP). BGS-FP service is the name of the rate plan for those residential and small commercial customers who choose not to use a competitive supplier for their electricity needs. Synapse's BGS procurement analysis takes into consideration the BGS auction process and other factors relevant to procurement options for NJ BGS customers. Synapse's analyses include assessment of procurement options in other states; futures markets for electricity, natural gas, and coal; recent auction/RFP results for BGS-FP-equivalent services from other states; PJM technical issues affecting BGS procurement considerations; and other relevant issues. Project work for the 2012 proceeding completed in April 2013.
Synapse provided expert technical consulting services to the Maryland Office of the People's Counsel related to Exelon Corporation’s proposed acquisition of Pepco Holdings Incorporated. Specifically, Synapse reviewed the Joint Applicants' economic impact analysis and concerns regarding concentration of ownership, market power, and market manipulation in the wholesale electricity market. Synapse submitted testimony in the legal proceeding on behalf of the MD OPC. Synapse performed similar analysis related to the merger on behalf of clients in Delaware, New Jersey, and the District of Columbia.
Direct Testimony of Paul Peterson on Market Power Issues Related to the Exelon-Pepco Merger in Maryland
Surrebuttal Testimony of Tyler Comings Regarding Economic Impact Analysis in Proposed Exelon-PHI Merger in Maryland
Surrebuttal Testimony of Paul Peterson on Market Power Issues Related to the Exelon-Pepco Merger in Maryland
Synapse provided expert technical consulting services to the New Jersey Division of Rate Counsel related to Exelon Corporation’s proposed acquisition of Pepco Holdings. Specifically, Synapse reviewed the Joint Applicants' economic impact analysis; merger-related reliability issues; and concerns regarding concentration of ownership, market power, and market manipulation. Synapse submitted testimony in the legal proceeding on behalf of the NJ DRC. Synapse performed similar analysis related to the merger on behalf of clients in Delaware, Maryland, and the District of Columbia.
Direct Testimony of Paul Peterson on Market Power Issues Related to the Exelon-Pepco Merger in New Jersey
Direct Testimony of Tyler Comings Regarding Economic Impact Analysis in Proposed Exelon-PHI Merger in New Jersey
The Center for Rural Affairs required technical assistance regarding the future of the Nebraska Public Power District (NPPD)‐owned Sheldon Station generating plant, including research, analysis, and findings presented in a report. Synapse detailed Sheldon’s future capital and operating costs and generation benefits, presented a list of credible options for NPPD’s replacement of Sheldon, and documented these findings in a clear, concise manner.
Synapse researched Sheldon’s future costs (i.e., costs driven by environmental regulation, market forces, and daily operations), as well as estimated the benefits NPPD gained by the plant’s operation, including those related to NPPD’s energy, capacity, and reliability needs. Synapse then outlined Nebraska‐specific options for alternatives, including energy efficiency, wind or solar photovoltaic generation, natural gas generation, market purchases, and/or transmission upgrades.
Synapse is actively working with a group of stakeholders to engage in the development of the Energy Information Administration's 2016 Annual Energy Outlook (AEO), to be released in mid-2016. The AEO is a critical source of publicly available information for public interest stakeholders working to improve planning and decision-making in the energy sector. Synapse is participating in working groups associated with three key areas of the 2016 AEO: the renewable energy sector, the electricity sector, and the residential/commercial buildings sector. Modeling of EPA’s Clean Power Plan will be a major change in the 2016 AEO from previous forecasts. Synapse is working with other stakeholders to participate actively in this process and advocate for reasonable policy and technology assumptions.
AEO Buildings Working Group Meeting Notes - February 18, 2016
AEO Electricity Working Group Meeting Notes - February 10, 2016
AEO Renewables Working Group Meeting Notes - February 9, 2016
AEO Buildings Working Group Meeting Notes – December 8, 2015
AEO Electricity Working Group Meeting Notes – December 8, 2015
AEO Renewable Working Group Meeting Notes – December 7, 2015
Synapse modeled various Clean Power Plan compliance options to determine how big an impact strong energy efficiency policies can have on the achievability and affordability of complying with EPA’s rule. Using the Synapse Clean Power Plan Toolkit, a collection of purpose-built in-house tools and commercial models, including the National Renewable Energy Laboratory’s Regional Energy Deployment System (ReEDS) model, Synapse examined the comparative cost of state implementation plans that maximize available energy efficiency strategies versus a future in which states are not Clean Power Plan‐compliant. Synapse modeled and found savings for each of the 48 continental U.S. states.
The results, updated in the factsheet and accompanying report below, show that if states comply using strategies that encourage cost‐effective energy efficiency, households can save on electricity bills.
Synapse held a series of public webinars on this topic:
- Bill Impacts of the Clean Power Plan Updated -March 17, 2016 View presentation here
- Bill Impacts of the Clean Power Plan - January 14, 2016 | 2 PM EST | View presentation here
- Bill Impacts of the Clean Power Plan (Repeated) - January 19, 2016 | 2 PM EST
Stopping the Clean Power Plan Raises Bills
Cutting Electric Bills with the Clean Power Plan Updated
The Clean Power Plan: Green and Affordable (factsheet)
Cutting Electric Bills with the Clean Power Plan
Cutting Electric Bills with the Clean Power Plan - January 15 Errata
Bill Impacts and the Clean Power Plan (webinar slides)
Synapse prepared two expert reports to be presented in annual property tax assessment cases relating to the valuation of the Byron Nuclear Power Station. The first gives a history of electricity restructuring, its effect on nuclear generation, and its impact on Illinois and the Byron station in particular. The second report rebuts the argument made by Concentric Energy Advisors that nuclear plants that are members of fleets enjoy superior historical performance due to this membership, and that the value of Byron station should thus be adjusted downward when assessing its worth to a non-fleet buyer.
Synapse and other supporting organizations—MassEnergy, Northeast Energy Efficiency Partnerships, and the Environment Economics & Society Institute—hosted a free, one-day training program for local environmental advocates interested in expanding their technical knowledge in order to become more effective intervenors and stakeholders.
Topics covered included the history and future of New England’s electric sector; supply and demand of energy in New England; the ISO and wholesale energy markets; current electric planning in New England; resource choices; and planning for greenhouse gas compliance.
Synapse assisted the Ohio Office of Consumer Counsel with issues related to EPA’s Clean Power Plan. This work included providing consultation and analysis on the plan’s costs to Ohio consumers, allowance trading, energy efficiency as a compliance option, and the impacts of compliance pathways on bills and emissions.
Synapse supported the National Association of State Utility Consumer Advocates and its members in addressing the EPA’s proposed Clean Power Plan in a manner that is cost-effective and efficient from an electricity consumer perspective.
Prior to the release of the rule, Synapse presented to NASUCA members key issues regarding the details of the proposed rule and the primary compliance options that may be available to states. Following the rule’s release, Synapse prepared a report focusing on the details of the rule as proposed. Recognizing that stakeholders have a wide range of reactions to the EPA’s Plan, the intent of the report is to be a common resource to help all of NASUCA’s members think through a broad range of potential implications of various compliance approaches to their respective consumers—whatever their individual state’s positions. Synapse presented on the findings of Implications of EPA’s Proposed “Clean Power Plan” at the 2014 NASUCA annual meeting in San Francisco, CA.
Synapse used its Clean Power Plan Planning Tool (CP3T) to perform multi-state analysis of the proposed rule to identify and explain a variety of challenges and opportunities related to multi-state compliance, including how states with dissimilar renewable technical potential, states with utilities that cross state boundaries, states with existing mechanisms for cooperation, etc., may approach regional compliance with the Clean Power Plan. Pat Knight, the lead developer of CP3T, provided a webinar for NASUCA members giving an overview of key issues surrounding the Clean Power Plan, as well as a walkthrough of CP3T’s multi-state functionality. Synapse also prepared a report presenting the results of the analysis, presented at the NASUCA 2015 Mid-Year Meeting.
As a third element of Synapse’s Clean Power Plan support to NASUCA members, Synapse prepared a report on best practices in planning for implementation of the Clean Power Plan. The report serves as a guide for consumer advocates to the logistics of developing a state implementation plan, with advice in areas such as stakeholder engagement, evaluating resource options, deciding on reasonable assumptions, identifying appropriate modeling tools, and selecting and implementing a plan.
This work was made possible by a grant from The Energy Foundation.
Best Practices in Planning for Clean Power Plan Compliance
Final Report: Implications of EPAs Proposed "Clean Power Plan"
Clean Power Plan: Key Issues for Consumers (slides)
Clean Power Plan: A Toolkit for State Compliance (slides)
Multi-State Compliance and CP3T (slides)
Comments on Best Practices Report and Multi-State Analysis (slides)
Best Practices in Clean Power Plan Planning (slides)
Multi-State Compliance with the Clean Power Plan in CP3T
Synapse prepared a series of briefs on the electric sector costs to consumers of low-emissions futures. The briefs are informed by modeling studies that investigate the costs of EPA’s Clean Power Plan, as well as a scenario in which we achieve low-cost emissions reductions even greater than those called for by the EPA.
Synapse used NREL's Regional Energy Deployment System (ReEDS) model to compare the costs of the U.S. electric sector transitioning to a Clean Energy Future with business‐as‐usual costs. In the Clean Energy Future, renewables grow rapidly to reach 70 percent of all generation by 2040, including nearly 200 GW of rooftop solar panels. Electricity sales are 25 percent lower than business-as-usual in 2040 as a result of savings from energy efficiency measures and standards, as well as demand response programs that pay participating consumers to curtail their energy use at times of peak demand. All coal-fired units built before 2005 are retired by 2040. This results in carbon dioxide emissions 84 percent lower than business-as-usual levels in 2040. Synapse found that consumers can save $41 billion in the year 2040 as compared to business as usual if states pursue these clean energy options.
The briefs and the associated background reports can be found below, along with recordings of webinars presenting the results.
Please note: Earlier versions of the publications found below reported 80-year lifetimes for nuclear units in both the reference and Clean Energy Future scenarios. In this analysis, nuclear power plants are actually assumed to retire after 60 years, after receiving one license extension from the Nuclear Regulatory Commission.
July 28 Webinar
September 3 Webinar
Telepresser
Clean Energy Future Technical Review: Brief #1 Background Report
Lower Costs Low Emissions Errata
Brief #2: Clean Power Means Lower Bills for Consumers
Bill Savings in a Clean Energy Future: Brief #2 Background Report
Bill Savings in a Clean Energy Future (July 28 Webinar Slides)
Understanding Clean Power Plan Compliance Paths
Brief #3: How Clean Power Will Save Us Money in the Long Run
Bill Savings in a Clean Energy Future, Part 2: Clean Power Plan Final Rule Update
Final Clean Power Plan: Modeling Costs to Consumers (September 3 webinar slides)
Synapse critiqued industry claims that a small, sensible change in Food and Drug Administration (FDA) regulations will add billions of dollars to the costs of prescription drugs. Currently, generic drug producers are required to use exactly the same label and warnings as the brand-name version of the same drug; the Supreme Court has held that, as a result, the generic producers cannot be held liable for failure to warn their customers of known drug hazards if the warnings do not appear on the brand-name label. Generic drugs account for most prescriptions filled in the U.S., and brand-name production often ceases when generics enter the market. This often means that the brand-name label, and hence the identical generic labels, are no longer updated when new information is discovered about drug hazards.
FDA proposes to change its rules to allow generic drug producers to update their own labels. The drug industry claims this will cause huge increases in the cost of generic drugs. At the request of the American Association for Justice (AAJ, formerly the American Trial Lawyers Association), Synapse evaluated the costs and benefits of generic drug regulation, and critiqued industry arguments against the FDA rule change.
A key benefit of renewable energy is that electricity generated from new renewable resources displaces electricity generated from other types of power plants. In doing so, renewables reduce the consumption of fossil fuel and production of fossil fuel-related carbon dioxide emissions. In the Clean Power Plan originally proposed by EPA in June 2014, this effect was ignored when setting emissions targets for states: EPA’s formula omitted this effect. In the final version of the rule, released August 3, states’ targets do account for emissions displaced by renewable generation.
As part of our ongoing series of webinars on EPA’s Clean Power Plan, Synapse hosted a webinar on how displacement occurs within the electric power system, and what this means for final targets set by EPA as well as states’ compliance with the rule. Panelists included authors of the Synapse report Air Emissions Displacement by Energy Efficiency and Renewable Energy, a survey of evidence that renewable resources and energy efficiency have indeed displaced fossil fuel resources connected to the grid.
Synapse reviewed the incorporation of end-use components into the Nova Scotia load forecasting modeling.
Synapse helped the Maryland Office of Peoples Counsel evaluate five categories of metrics for smart grid initiatives proposed by BG&E and PEPCO: reductions in energy prices, avoided capacity costs and reductions in capacity prices as a result of reductions in energy use enabled by smart grid initiatives such as peak time rebates (PTR), and reports to customers on their energy usage, and Conservation Voltage Reduction.
Sierra Club retained Synapse to evaluate Kansas City Power & Light’s economic justification for environmental retrofits at the La Cygne Generating Station, for which KCP&L is requesting capital recovery in a case before the Missouri Public Service Commission. The retrofits for La Cygne, which is on the Kansas/Missouri border, were pre-approved by the Kansas Corporation Commission in 2011. After reviewing KCP&L’s original application, modeling files and associated work papers, the monthly status reports on the La Cygne environmental retrofits, and other materials, Synapse found that the original analysis of the retrofits was imprudent and that market conditions have changes significantly in the electric sector in 2011 and 2012, warranting a reevaluation of that analysis.
Surrebuttal Testimony of Rachel Wilson on the Prudence of Environmental Retrofits at KCP&L La Cygne Generating Station
The widely cited FUND model of climate economics estimates that climate change will have less serious impacts, and that the optimal policy is to do less, than implied by many other analyses. Synapse's Frank Ackerman together with subcontractor Charles Munitz explored the FUND model, testing combinations of inputs that may illuminate the sources of FUND's distinct forecasts.
Synapse worked with REMI to conduct a national analysis of a fee-and-dividend carbon policy. Synapse used the ReEDS model at the state level in order to assist REMI in a macroeconomic analysis of the impacts of such a policy. Synapse defined modeling scenarios and assumptions with input from REMI; performed five model runs; and provided generation, capacity, and emissions outputs that were used as inputs to the REMI model.
On behalf of the Mountain Association for Community Economic Development (MACED), Synapse performed an analysis of the long-standing problem of disappearing coal jobs in eastern Kentucky. We then examined options for alternative employment based on six possible growth industries identified by MACED: energy efficiency, local food production, health care, sustainable forestry and wood products, tourism, and environmental remediation. Synapse developed scenarios for growth, based on the regional potential for expansion and the estimated costs and potential of each industry. We completed the technical analysis using IMPLAN, a well-known economic impact model. Specifically, we modeled a scenario that creates enough new jobs in these growth areas by 2030 to replace half of the remaining coal jobs and also bring the region’s unemployment levels down to the national average. The project received generous support from the Environment, Economics, and Society Institute (EESI).
Synapse worked with Meister Consulting Group to analyze the Clean Energy Plan of Lincoln Electric System (LES), the customer-owner municipal utility for the city of Lincoln, Nebraska, on behalf of Sierra Club. Historically, LES has generated about 85 percent of its electricity from coal-fired power plants. Synapse and Meister used LES’s Clean Energy Plan to develop a set of scenarios examining the bulk power costs (including costs of complying with upcoming environmental regulations) and monthly bill impacts of LES maintaining its coal-focused status quo. The project team also examined alternatives in which LES pursues expanded renewable energy PPAs.