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.
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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
Synapse hosted a set of webinars and prepared a factsheet on community and environmental justice issues in the Clean Power Plan. EPA requires states to engage vulnerable communities—including low‐income residents, communities of color, and/or tribal communities—when developing compliance plans. In addition, EPA will allow states to opt into a Clean Energy Incentive Program (CEIP) that rewards renewable energy projects and low-income energy efficiency programs initiated before the first compliance period.
Synapse’s first webinar on this topic focused on the CEIP, addressing questions about resources eligible for CEIP credits, the allocation of credits from states and EPA, and the benefits and risks of participating in the program. The second webinar discussed broader environmental justice issues and states’ requirements during compliance plan submittal. For example, states must provide names of community groups, the state’s method for identifying these groups, and the mechanisms for engaging them.
Environmental Justice and the Clean Power Plan (December 8 webinar slides)
Understanding the Clean Energy Incentive Program (November 17 webinar slides)
In 2016, Synapse provided a report estimating the net savings for a typical car and light truck owner associated with compliance with proposed federal fuel economy standards for 2025. In March 2017, Synapse conducted additional analyses addressing automaker claims that the fuel economy standards hurt households and affordability of new vehicles. We found that actual fuel economy improvement in the last ten years has saved households’ bottom line.
More Mileage for Your Money
Synapse reviewed assumptions in Delmarva Power and Light’s benefit-to-cost analysis of its Advanced Metering Infrastructure (AMI) Initiative. Max Chang submitted testimony on behalf of Maryland OPC demonstrating that, due to unreasonable assumptions, DPL overestimated the benefit to cost ratio of the AMI program for the 2015-2024 period. Mr. Chang recommended that the Commission disallow $34 million in order to protect ratepayers.
The Rhode Island Energy Efficiency & Resource Management Council (RI EERMC) and other stakeholders have begun exploring ways to encourage demand response at residential and small commercial sites in Rhode Island. Synapse provided technical expertise to RI EERMC throughout this collaborative process, first drafting a report that summarized demand response in New England over the previous six years. The report detailed (1) the participation of demand response in the forward capacity market, (2) the major demand response providers working with customers to provide demand response to the wholesale markets, and (3) customers who typically benefit from that partnership. Synapse then helped RI EERMC identify issues to address with its stakeholder group, including opportunities for demand response in Rhode Island and options for pilot project design. The final stage focused on using a consumer technology adoption model to engage these customers.
Demand Response: Scoping the Opportunity for Rhode Island (slide deck)
Technology Adoption for Small Customer Demand Response
On behalf of the Office of the People's Counsel for the District of Columbia (OPC), Synapse evaluated several aspects of distributed generation in Washington, DC. This project consisted of three research topics. First, Synapse researched and offered recommendations regarding policies that can sustainably support the development of distributed generation in the District, while avoiding adverse consequences. Second, Synapse assessed the technical and economic potential for distributed generation in the District, particularly solar photovoltaics (PV). Finally, Synapse conducted a benefit-cost analysis of solar in the District.
OPC Reply Comments Regarding Pepco Comments on Value of Solar Study
The Dakota Access pipeline, proposed in 2014, was designed to carry crude oil from the Bakken oil field in western North Dakota, through South Dakota and Iowa, to a pipeline hub in southern Illinois. The final stages of construction, not yet completed, have become the subject of a wide-ranging controversy involving multiple environmental, legal, cultural, and economic issues.
In February 2017 Synapse produced a report based on research performed for Fredericks Peebles & Morgan LLP, attorneys for the Cheyenne River Sioux, addressing one dimension of the controversy: the economic impacts of completing the Dakota Access pipeline.
Synapse was hired by NRDC's Sustainable FERC Project to assist them in convincing PJM staff and stakeholders that their load forecasting process should include a forecast of future energy efficiency. Ultimately PJM staff proposed their own method of including an EE forecast in their load forecasting methodology. Synapse reviewed PJM’s proposed method and welcomed their approach. An initial forecast of solar PV installations has also been included.
On behalf of the Nova Scotia Utility and Review Board, Synapse reviewed the demand-side management plan filed by EfficiencyOne for 2016-2018. Tim Woolf submitted direct testimony to the Board on the appropriateness of the budget and savings levels, addressing affordability, cost-effectiveness screening, and bill impact analyses. Mr. Woolf’s testimony finds that EfficiencyOne’s plan is cost-effective and affordable, and could be expanded to reach higher energy savings levels without resulting in large or undue short-term rate increases.
Synapse, through its subcontractor John Rosenkranz, analyzed and reviewed Elizabethtown Gas’s petition to the New Jersey Board of Public Utilities for the review of its Period Basic Gas Supply Service Rate.
Energy efficiency is widely recognized as an abundant and low-cost option for complying with the requirements of EPA’s Clean Power Plan. Whether states choose a mass-based or a rate-based approach to compliance, energy efficiency should be the primary strategy for complying with the Clean Power Plan. However, not all electric customers have equal access to customer-funded efficiency programs. Concerns about fairness between customers—those who participate in programs and see greater benefits than those who do not—create a barrier to widespread implementation of energy efficiency programs.
Synapse developed a handbook that outlines ten strategies to mitigate concerns about fairness between customers. The handbook—a resource for state legislators, public utility commissions, local governments, program administrators, and other stakeholders—discusses each strategy in detail, including how it promotes fairness, its potential to save more energy, the actions states must take to put the strategy in place, and examples of entities that have already implemented these strategies.
Synapse also released an accompanying factsheet that discusses the key concepts driving these strategies and describes how states can leverage the Clean Power Plan to generate additional funds for energy efficiency programs.
Energy Efficiency and the Clean Power Plan (factsheet)
Energy Efficiency and the Clean Power Plan (December 15 webinar slides)
To assist Prince Edward Island Regulatory & Appeals Commission in reviewing Maritime Electric's five-year plan, Commission staff sought independent advice on various demand-side management program issues. For the Commission staff, Synapse prepared a comprehensive, best practice report that details key principles of various energy efficiency program and policy requirements, as well as key principles of rate design for encouraging energy efficiency and conservation. This report also provides examples from other jurisdictions and recommendations for how PEI should move forward. Specific topics included in this report are: (1) program planning and review processes, (2) program design, (3) cost-effectiveness screening, (4) multi-year planning and savings targets, (5) cost recovery, (6) shareholder incentives, (7) stakeholder input, (8) evaluation, measurement, and verification, and (9) electricity tariffs to encourage energy efficiency and conservation.
As a continuation of previous work, Synapse provided NS UARB with consulting services on energy efficiency issues. Specifically, Synapse provided technical support and analysis with respect to rate and bill impacts, low-income program participation and performance, methodology to determine program incentives, and benefits of location-specific efficiency targeting.
Reply Comments on CLEAResult EfficiencyOne Incentive Setting Methodology
Comments on Revised CLEAResult EfficiencyOne Incentive Setting Methodology
Comments on EfficiencyOne 2016 Rate and Bill Impact Analysis
Comments on Efficiency Nova Scotia 2017 DSM Progress Report
Serious, imminent, and irreversible damages to natural ecosystems, infrastructure, agricultural production, and human health make dramatic reduction of greenhouse gas emissions a key priority for communities around the world. Most greenhouse gases are emitted as a result of our use of energy, and the Commonwealth of Pennsylvania is no exception in this regard. Delaware Riverkeeper Network asked Synapse Energy Economics and EQ Research to find a path forward that will enable Pennsylvania to serve its energy needs entirely with clean, zero‐emission renewables by 2050.
On October 20, 2016, Synapse joined EQ Research and Delaware Riverkeeper Network to present a public webinar discussing the report. A recording is available on Delaware Riverkeeper Network's website.
Press Conference: "Envisioning Pennsylvania's Energy Future" Report Release
Envisioning PAs Energy Future (Public Webinar Slides)
On behalf of the Sierra Club, Synapse conducted an in-depth assessment of the recent and forward-going economics of the North Valmy Generating Station, a 522 megawatt, two-unit coal plant located in Valmy, Nevada. Additional transmission investments, declining natural gas prices, and environmental regulations have bolstered the economic argument for the plant’s early retirement. Synapse’s report recommends a secure, near-term retirement date that will enable the companies and regulators to coordinate more prudent planning.
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
FirstEnergy’s Ohio utilities (Ohio Edison, Cleveland Electric, and Toledo Edison) filed an application before the Public Utility Commission of Ohio seeking approval of an Electric Security Plan (“ESP”) and related Retail Rate Stability Rider (“Rider RRS”). FirstEnergy claims that customers will receive benefits of over $2 billion over the length of the plan due to the Companies’ projections of revenues from capacity and energy market sales. On behalf of Sierra Club, Synapse expert witness Tyler Comings submitted testimony focusing on the assumptions and analysis used by the Companies to support the Rider RRS, and the policy implications and risks associated with the proposed transaction.
Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Second Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Third Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Rehearing Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Recently, there has been a substantial increase in the number of utilities that propose to recover more of their costs through monthly fixed charges rather than through variable rates. Synapse prepared a report for Consumers Union that documents the current trend toward utilities proposing substantial increases in fixed electricity charges, describes the theoretical flaws behind fixed charges, analyzes their impact on consumers, and proposes alternatives.
Synapse and Consumers Union held a webinar on February 10, 2016 based on the report: Caught in a Fix: The Problem with Fixed Charges for Electricity.
Caught in a Fix: The Problem with Fixed Charges for Electricity
Caught in a Fix - Webinar Slides
Synapse provided technical support for Sierra Club’s participation in the Florida Power & Light (FPL) 2016 Rate Case. Synapse reviewed three major capital investments included in FPL’s 2016 10-Year Site Plan: $800 million to replace retiring gas turbines; $450 million to upgrade combustion turbine compressors; and $400 million to build three solar plants (224 MW combined). The analysis addressed whether FPL considered lower cost, lower risk alternatives to meet its planning reserve margin goal, whether new units were necessary to meet its goal, and whether solar resources could have been procured at lower cost.
Synapse supported Sierra Club in the evaluation of the Georgia Power 2016 Integrated Resource Plan. Specifically, Synapse reviewed Georgia Power Company’s Unit Retirement Study (URS), which was conducted by the company to assess the economic benefit of continuing operation of its major fossil fuel power plants. Based on the URS, Georgia Power recommended decertifying one coal-fired unit and four combustion turbines. Synapse’s analysis of the URS uncovered substantial issues with its model and assumptions. Dr. Jeremy Fisher and Tim Woolf submitted expert testimony demonstrating that, contrary to Georgia Power’s URS findings, eight generators are not economically viable.
Exhibits for Direct Testimony of Jeremy Fisher regarding Georgia Power 2016 Integrated Resource Plan
Massachusetts’ Green Communities program helps the state’s 351 cities and towns find and successfully implement clean energy solutions. To receive Green Community designation, communities must develop and implement a plan to reduce energy use by 20 percent within five years and meet additional criteria including allowing for permitting and siting of renewable energy, purchasing fuel-efficient and alternative fuel vehicles, and adopting more stringent building codes. The Massachusetts Department of Energy Resources engaged Synapse to review Green Community Annual Reports, verify whether municipalities have reached their 20 percent energy reduction goal, and develop a Progress Report for the program highlighting achievements to date. Synapse will also identify strategies that are effective across towns, provide support to towns to meet their energy reduction goal, and make recommendations to continue to advance and improve the program. Synapse developed the Green Communities Program 2016 Progress Report, available here, and is currently developing the 2017 report.
Southern Environmental Law Center retained Synapse to review Dominion Virginia Power’s application for a Certificate of Public Convenience and Necessity for its proposed Greensville County Power Station, a new natural gas combined-cycle plant. Synapse’s analysis found that the Company’s need analysis overstated its electric load and did not give appropriate consideration to alternative resource choices. On behalf of environmental respondents, Rachel Wilson submitted testimony to the Virginia State Corporation Commission demonstrating that Dominion overstated the need for the Greensville NGCC and recommending that the Commission deny the Company’s petition for a CPCN and an associated rate increase.
In collaboration with partners from Harvard University, the University of Delaware, and Boston University, Synapse modeled the climate, air quality, and health benefits of offshore wind facilities in the Mid-Atlantic United States. The study simulated benefits of offshore wind facilities of different sizes in two locations that are in early stages of planning and development. The results demonstrated that these offshore facilities can produce health and climate benefits of between $54 and $120 per MWh of generation. The project was a joint effort of Synapse, the Center for Health and the Global Environment at the Harvard T.H. Chan School of Public Health, the University of Delaware College of Earth, Ocean & Environment, and the Boston University School of Public Health Department of Environmental Health. Environmental Research Letters published the findings in its July 2016 volume.
On behalf of Not Another Power Plant and Sierra Club, Synapse’s Bob Fagan submitted Direct and Surrebuttal expert testimony to the Connecticut Siting Council regarding the Killingly Energy Center, a 550 MW combined cycle power plant proposed for Killingly, Connecticut. He testified at two separate Siting Council hearings concerning the proposed plant. Mr. Fagan’s testimony clearly demonstrated that there are no short-term or longer-term reliability needs for the proposed plant. Further, increased renewable resources and energy efficiency required to meet increasing greenhouse gas emission limits will provide more than sufficient energy and capacity to meet reliability needs.
Surrebuttal Testimony of Bob Fagan Regarding Proposed Killingly Energy Center
The Midwest Renewable Energy Tracking System (M-RETS) tracks information about renewable energy production and delivery in participating states and provinces (Illinois, Indiana, Iowa, Manitoba, Minnesota, Montana, North Dakota, Ohio, South Dakota, and Wisconsin). The Fee Structure Model (FSM) is a tool first developed by Synapse for M-RETS in September 2012. The FSM uses historical data from both publicly available sources and M-RETS internal tracking to project future annual revenues. A key part of this forecast is an annual calibration of the tool to determine whether significant revisions should be made to the FSM. In its comparison of 2015 projected vs actual revenues, Synapse identified and then addressed two areas for updates in 2016, subscriptions and voluntary retirements.
Synapse is providing technical support and expert testimony to the Conservation Law Foundation regarding a series of Massachusetts Department of Public Utilities natural gas pipeline dockets. In these dockets, electric distribution companies have petitioned to embed the costs of natural gas transmission pipelines in customer electric bills. In the most recent dockets (MA 15-181 and MA 16-05), Eversource and National Grid submitted separate analyses on the long-term economic benefits of Algonquin’s proposed Access Northeast natural gas pipeline infrastructure project. Synapse assessed the methodology and assumptions of the benefits in the analyses submitted by Eversource and National Grid. Specifically, Synapse reviewed the results of scenarios modeling New England’s future electric sector with and without the Access Northeast pipeline to determine whether the modeling assumptions (1) were consistent with compliance with state and federal environmental laws and (2) represented “most likely” projections of uncertain future conditions.
Direct Testimony of Elizabeth A. Stanton Regarding the National Grid Analysis of Economic Benefits of Proposed Access Northeast Gas Pipeline
Synapse provided expert support to the Conservation Law Foundation (CLF) in its New Source Review (NSR) suit over modifications made to Merrimack Station Unit 2 in New Hampshire.
South Carolina Electric and Gas Company (SCE&G) filed a petition (Docket No. 2016-224-E) requesting that the Public Service Commission of South Carolina approve an approximately $852 million increase in the cost estimate for the construction of two new units at the V.C. Summer nuclear power plant. SCE&G has repeatedly raised rates to recover financing costs of the plant, resulting in a substantial impact on customer bills. South Carolina Coastal Conservation League (SCCCL) retained Synapse to analyze the opportunity for energy efficiency programs to mitigate the bill increases associated with SCE&G’s petition. On behalf of SCCCL, Senior Associate Alice Napoleon submitted testimony and an accompanying report in which she reviewed SCE&G’s energy efficiency efforts to date and presented recommendations for expanding SCE&G’s energy efficiency programs in order to provide all customers with opportunities to lower their bills.
Direct Testimony of Alice Napoleon regarding South Carolina Electric and Gas Energy Efficiency Efforts
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.
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