Synapse provided services to the Pennsylvania Office of the Consumer Advocate regarding several wholesale power system issues. Our major focus was on PJM’s Reliability Pricing Model (RPM) proposal for a new capacity market structure. Our work in this regard included participation in settlement discussions in the summer and fall of 2007, as well as significant effort on developing a process for implementing reliability and economic transmission system upgrades and the cost allocation metric associated with those upgrades. In addition, we perform periodic work on Market Monitoring and Demand Resource issues.
Clean energy programs and policies can help states achieve their goal of providing a less polluting, reliable, and affordable energy system. Working under Stratus Consulting, Synapse jointly authored a guidebook for evaluating energy system impacts and air emissions reductions from implementing clean energy measures. This guidebook introduces state policymakers and analysts to the concepts, terms, methods, tools, assumptions and models that Public Utility Commissions and utilities use to compare traditional grid electricity with demand and supply-side clean energy resources (e.g., energy efficiency, renewable energy, CHP, and clean distributed generation). Short examples and case studies illustrate the challenges that states face in analyzing clean energy initiatives, as well as the methods they have used to successfully quantify and promote them.
Synapse was retained to collaborate with Nova Scotia Power on its Integrated Resource Planning process. Synapse reviewed the input assumptions and developed a modeling plan. The IRP analysis used the Strategist model. Synapse's work on this IRP included research on a wide range of issues, including the DSM potential study, the fuel price forecasts, the construction costs of new generating capacity, the integration of variable output wind to the NS grid, the prospects for and implications of future carbon emissions regulations, and the evaluation of alternate resource plans.
Evidence of David Nichols Regarding Nova Scotia Power Inc Demand Side Management Plan
For Niagara Mohawk service territory in New York State, Synapse developed projections of electric energy and capacity costs which will be avoided due to reductions in electricity use and natural gas costs that will be avoided due to reductions in natural gas use. Deliverables included detailed projections for an initial fifteen year period beginning in 2007 and escalation rates for another fifteen years from 2022 through 2037.
For this project, Synapse performed a detailed analysis of the impacts of distributed generation resources on wholesale electric energy prices and air emissions in Massachusetts. Impacts analyzed include potential reductions on the level of wholesale electricity market prices and associated air emissions.
Synapse subcontracted to the Global Development and Environment Institute (GDAE) at Tufts University to write a chapter on the costs and risks of climate change to the electricity energy sector for a report presented by the NRDC. The chapter explored current energy infrastructure in the US and how it might be put at risk from climate change, as well as how energy use could be expected to change under a changing climate. Synapse created a regionally explicit model of hourly energy use in 2005, and applied expected seasonal temperature changes to each region to estimate expected per-capita energy consumption in 2025, 2050, 2075, and 2100. With energy consumption increasing during summer peak periods in warm climates, the costs of procuring power in the south (Florida in particular) and southwest (S. California) resulted in high costs to consumers in those regions. Lower consumption of electricity, gas, and oil in northern latitudes provided net savings for a limited number of consumers. Ultimately, the analysis concluded that climate change could result in net costs of $28 billion per annum by 2025 and $141 billion per annum by 2100. These costs did not include the risk of losing coastal power plants and other infrastructure to coastal flooding. To view the results of the project, please visit http://www.nrdc.org/globalwarming/cost/contents.asp.
Synapse was hired to prepare an expert reports on electric power system issues related to the EPA New Source Review. Bruce Biewald testified in a deposition prior to the settlement of the case. Project completed in July 2007.
For this project, Synapse reviewed a ISO-NE Scenario Analysis report and developed a Companion Report that evaluated two additional scenarios for greater EE, DR, renewables, and reduced carbon resources.
Synapse represented the staff of the Pennsylvania Office of Consumer Advocate in the demand-side management (DSM) and advanced metering infrastructure (AMI) workgroup. We reviewed various aspects of DSM and AMI initiatives, prepared documents on good practices in these areas, recommended specific programs from other states, and participated in the workgroup.
Synapse was hired by a coalition of public interest organizations to review the proposal by Duke Energy Indiana and Vectren to invest approximately $2 billion in a new integrated gasification combined cycle (IGCC) coal power plant at Edwardsport. The project included analysis and testimony by Bruce Biewald on computer modeling and resource planning, levelized cost comparisons, and ratemaking issues; by Phil Mosenthal of Optimal Energy on demand-side management potential and costs; Robert Fagan on renewable resource potential and costs; and David Schlissel on carbon dioxide regulations and power plant construction costs. The project team found that the Companies' planning for Edwardsport was inadequate, that the IGCC plant would increase dependence upon coal for electricity generation and would subject the Companies’ shareholders and customers to unnecessary costs and increased risks. Synapse witnesses recommended that the Commission reject the Companies’ request for approval of the proposal to construct and own the Edwardsport IGCC project, and instead require the Companies to do complete and proper planning which should include: (1) up-to-date construction cost estimates for IGCC and other resources; (2) analysis of the cost impacts on customers that reflect the ratemaking treatment that the Companies’ request be used for the resources; (3) use of a realistic range of low, mid, and high case projections for future carbon dioxide prices; (4) full consideration of cost-effective demand-side management, combined heat and power, and renewable resources, and (5) a proper risk analysis that recognizes a range of risks including but not limited to construction cost overruns and project delays as well as fuel prices and environmental compliance requirements.
Direct Testimony of Robert Fagan Reviewing the IGCC Plant Proposal by Duke Energy Indiana and Vectren
Exhibits of Robert Fagan for the Review of the IGCC Plant Proposal by Duke Energy Indiana and Vectren
Direct Testimony of David Schlissel Reviewing the IGCC Plant Proposal by Duke Energy Indiana and Vectren
Cross Answering Testimony of Bruce Biewald Reviewing the IGCC Plant Proposal by Duke Energy Indiana and Vectren
Assist Staff of the Arkansas Public Service Commission as a subcontractor to Larkin Associates on a range of electric resource planning and power procurement issues over the year July 2006 through June 2007. Specific tasks included assistance with development of resource planning guidelines for electric utilities, testimony regarding the reasonableness of the proposal by Oklahoma Gas and Electric Company to acquire additional wind and gas-fired generating capacity, preparation of a background report on fuel diversity policies and practices to assist the Commission in its determination of whether to recommend the adoption of a fuel diversity standard under the Energy Policy Act of 2005 (EPAct 2005). Advice to Staff in their assessment of SWEPCo’s proposal to construct a new coal-fired generating unit.
Synapse examined three interrelated British Columbia wind power issues for a group of BC environmental organizations and provided expert witness testimony. We analyzed BC Hydro's $3/MWh "firming" premium used at the evaluation stage of their 2006 RFP for energy resources. Synapse also reviewed the liquidated damages (LD) provisions of BC Hydro's standard contract for wind energy providers and summarized existing wind integration operational cost studies. Synapse concluded that the firming premium is not supported as the storage and ramping capability of BC Hydro's hydroelectric resource base is more than sufficient to allow for monthly rather than hourly scheduling. Synapse also concluded that the LD provisions could cause wind projects to appear more expensive than they actually are. Lastly, Synapse recommended detailed technical analyses be conducted to analyze the impact of varying levels of wind penetration on BC Hydro's operational costs. The BC Commission order (May 2007) did direct BC Hydro to look carefully at wind capacity projections.
Synapse and researchers from the Harvard School of Public Health investigated the sources of fine particulate (i.e., PM2.5) emissions, both stationary and mobile, that affect New York City, and the impact of these PM2.5 emissions on air quality and health. The study also examined the potential control and mitigation measures that could be taken to reduce or offset PM2.5 emissions from all sources.
In order to address the effectiveness of LMP markets, Synapse was asked by the American Public Power Association (APPA) to review the theory and goals of the Locational Marginal Pricing (LMP) construct and to hold them up to the several years’ worth of experience in LMP markets. We asked the following questions: (1) Does security-constrained dispatch and LMP pricing work as well in the real world as it should in theory? (2) Have the price-signaling aspects of LMP produced the desired outcomes in terms of investments in electricity infrastructure? (3) Have the LMP markets been workably competitive, or is market power and price manipulation a concern? (4) Have power production costs come down as a result? Our results were presented at the Electricity Markets Reform Initiative (EMRI) symposium, hosted by APPA in Washington, DC on February 5, 2007.
LMP Electricity Markets: Market Operations, Market Power, and Value for Consumers Presentation
LMP Electricity Markets: Market Operations, Market Power, and Value for Consumers Article
Synapse provided an economic valuation of the Bellows Falls hydroelectric facility as of April 2006 for the Town of Rockingham, VT.
Assisted the valuation consultant retained by the Town of Jay by analyzing the expectations regarding the gas-fired cogeneration facility project's long-term annual revenues and operating costs for two set points in time.
Synapse provided the Ohio Office of the Consumer Counsel and other consumer advocates with assistance in evaluating PJM's proposed Reliability Pricing Model (RPM) for capacity markets. Synapse reviewed, proposed modifications, and intervened in a contested process at FERC to determine the final design of the RPM capacity market. Our efforts helped secure modifications to the model that will save state ratepayers in PJM hundreds of millions of dollars annually. In addition, Synapse assisted the Office with transmission planning for economic and reliability upgrades (including cost allocation).
Synapse provided the Office of the People's Counsel with assistance in evaluating PJM's proposed Reliability Pricing Model (RPM) for capacity markets. On behalf of DC OPC and other consumer advocates in the PJM wholesale power system, Synapse reviewed, proposed modifications, and intervened in a contested process at FERC to determine the final design of the RPM capacity market. Synapse provided assistance to DC OPC in all phases of the review, comments, technical conferences, and settlement processes, and our efforts helped secure modifications to the model that will save state ratepayers in PJM hundreds of millions of dollars annually. In addition, Synapse assisted the Office with transmission planning for economic and reliability upgrades (including cost allocation).
Synapse was retained to analyze and critique NSPI's application for an air emissions strategy to meet Provincial emission compliance regulations. Our focus was upon the alternatives and methodology used by NSPI to determine its preferred option for SO2 and NOX reduction. We reviewed the Company's STRATEGIST model runs.
Supplemental Evidence Regarding the Review of NSPI Emissions Compliance Plan
After a Technical Conference in February 2006 on PJM capacity market and reliability issues, FERC provided a comment period for parties to make supplemental statements. Synapse assisted a broad coalition of PJM Members (Coalition of Consumers for Reliability, CCR) in developing Comments. Synapse also provided an affidavit from Ezra Hausman that described concerns with PJM's process for establishing the "cost of new entry" (CONE) for a typical peaking unit. This specific project is part of a larger on-going effort that assists the Pennsylvania Office of Consumer Advocate with PJM wholesale market and bulk power transmission system issues. These Comments were filed in FERC Dockets ER05-1410-000 and EL05-148-000. Project completed in June 2006.
RPM 2006: Windfall Profits for Existing Base Load Units in PJM
Affidavit of Ezra Hausman for FERC Technical Conference on RPM
Post-Technical Conference Comments on FERC Technical Conference on RPM
Pre-Conference Comments on FERC Technical Conference on Proposed Variable Resource Requirement (VRR) Curve in PJM
Post-Technical Comments on FERC Technical Conference on Proposed Variable Resource Requirement (VRR) Curve in PJM
Synapse was asked by the United States EPA to develop content for the EPA's Clean Energy Website on the calculation and evaluation of displaced pollutant emissions resulting from energy efficiency and renewable energy initiatives. The website content includes a description of several approaches that could be used to calculate displaced emissions, as well as descriptions of their applicability, resource requirements, and precision. The product is to be available as a "decision support" tool for anyone involved in energy efficiency or renewable energy projects to help them assess the emissions benefits of their efforts. Project completed in April 2006.
Synapse was asked to provide prefiled testimony in a 248 proceeding (Certificate of Public Need) on behalf of a private sector wind developer, outlining the economic and environmental benefits of a proposed wind farm in Deerfield, Vermont. Synapse evaluated the need for new energy resources in Vermont, the demand for renewable energy to fulfill state Renewable Portfolio Standards in the region, and the economic benefits of clean energy and displaced emissions. In addition, Synapse projected project costs and revenues to demonstrate the economic viability of the proposal. Project completed in March 2006.
Synapse was asked to provide prefiled testimony in a 248 proceeding (Certificate of Public Need) on behalf of Catamount Energy, Inc., outlining the economic and environmental benefits of a proposed wind farm in Glebe Mountain, Vermont. Synapse evaluated the need for new energy resources in Vermont, the demand for renewable energy to fulfill state Renewable Portfolio Standards in the region, and the economic benefits of clean energy and displaced emissions. In addition, Synapse evaluated how the proposed project conformed to the Vermont Electric Plan. Project completed in April 2006.
Synapse assisted the Tallahassee electric company in preparing an integrated resource plan. We played an advisory role to the electric company planners in four ways:
- reviewing the potential for demand-side management,
- assisting in developing strategies to assess large amounts of energy efficiency and renewable resources,
- developing methods to account for environmental factors, including CO2 emissions, and
- developing methods for evaluating and selecting among different electricity resource options.
Project completed in September 2006.
Synapse worked with Resource Insight to analyze the market power implications of a proposed merger. Synapse ran the CASM model to estimate the Herfindahl-Hirschman Indexes for various scenarios with and without the merger. Project completed in March 2006.
As a result of the settlement agreement approved by the Federal Energy Regulatory Commission that allowed ISO-New England to develop and administer a Forward Capacity Market for New England, a potential new revenue stream for utility DSM programs was created. This created many new decisions for regulators regarding how programs should participate in the market and how the resulting revenues should be used. Synapse prepared a paper providing background and setting forth some of the options for regulators and program administrators.
Synapse was hired by the National Association of Regulatory Utility Commissioners (NARUC) to conduct an analysis and write a report on electricity portfolio management. Specifically, the paper critiques available models used for portfolio management and resource acquisition and provides advice for regulators on how to choose and utilize such models in making regulatory decisions. Measures for evaluating risks and hedging strategies are discussed, with an emphasis on the perspective of customers and regulators. Project completed in September 2006.
Portfolio Management: Tools and Practices for Regulators
Energy Portfolio Management: Tools and Resources for Regulators
Synapse investigated the market power effects of the proposed merger between Exelon Corporation and Public Service Enterprise Group. Synapse’s analysis included running CRAI’s CASM model, re-running delivered price test analysis by petitioners’ witness Frame, and modeling of market power impacts using ELMO. The results of Synapse's analyses were presented in affidavits to FERC and testimony before the New Jersey Board of Public Utilities. The companies terminated the proposed merger on September 16, 2006. Project completed in October 2006.
Examination of Proposed Merger of Public Service Enterprise Group (PSEG) and Exelon Corporation - Supplemental Testimony
Analysis of Market Power in the Exelon Corporation & Public Service Enterprise Group Merger
Direct Testimony In the Matter of the Joint Petition of PSEG and Exelon
Synapse examined the impact of a proposed state-specific Mercury emissions rule upon wholesale electricity market prices, competition, and retail electricity consumers in Illinois. In our testimony, we demonstrated how IPM model results obtained by ICF Corporation did a poor job of resolving state-specific economic and dispatch impacts of the proposed rule. To rectify this, we developed our own estimates of the likely direct and indirect economic implications of the rule for the state and the surrounding region. Synapse's research and analyses showed that the benefits of implementing this rule significantly outweighed the costs. As a result, a slightly modified version of the rule was accepted upon settlement by all affected utilities and the state. Project completed in September 2006.
Pursuant to a Vermont Public Service Board Order in Docket No. 7801, a mediated negotiation process was established to review the process by which VT electric utilities conduct transmission system planning with a particular focus on the evaluation of non-transmission alternatives (NTAs) that could include energy efficiency, demand response, or distributed generation resources. Synapse assisted CLF, a party to Docket 7801, in the mediated negotiation process. Synapse also provided direct and rebuttal testimony that urged the VT PSB to reject the proposed Memorandum of Understanding (MOU) submitted by the majority of the utility parties and the Department of Public Service. The VT PSB issued a decision on June 20, 2007. In the Order, the VT PSB largely accepted the provisions of the MOU and, after a lengthy discussion, rejected CLF’s positions. Project completed in December 2006.
Rebuttal Testimony Regarding the Review of Vermont Transmission Planning Process