Synapse provided expert witness testimony and analysis to Sierra Club for Southwestern Public Service Company's (SPS) 2019 rate case in the states of New Mexico and Texas. The case focused on the retirement date for the Tolk Plant, which the Company was requesting be moved up based on a water shortage in the region that would limit the ability for SPS to continue economically operating the plant year-round through its current retirement date. Synapse’s testimony and analysis focused on both the recent historical and future projected economic performance of Tolk under the Company’s proposed seasonal operations plan for the plant moving forward. We also evaluated the Harrington Coal-fired Power Plant. We found that both plants are likely to lose money going forward relative to alternatives and the market, and therefore SPS should develop a plan to retire both plants. SPS has been required to update its analysis on the future operation of the Tolk Power Station.
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Testimony of Devi Glick in Case No. 19-00170-UT
Direct Testimony of Devi Glick in PUC Docket No. 49831
On behalf of the Natural Resources Defense Council, Synapse is providing technical and policy support in a number of New York Public Service Commission (NY PSC) and Pennsylvania Public Utility Commission (PUC) proceedings.
In the ongoing Niagara Mohawk rate case before the NY PSC, Synapse filed testimony on earnings adjustment mechanisms to align utility incentives with New York's energy and climate goals.
In Pennsylvania, Synapse submitted testimony on the Act 129 Energy Efficiency and Conservation plans of PPL Electric Utilities Corporation and PECO Energy Company. Separately, Synapse assisted NRDC with developing comments for the PUC's proceeding on Utilization of Storage Resources as Electric Distribution Assets.
Revised Direct Testimony of Alice Napoleon and Kenji Takahashi In regard to PPL Electric Utilities’ proposed energy efficiency and conservation plan
Direct testimony of Alice Napoleon and Courtney Lane regarding PECO Energy's proposed energy efficiency and conservation plan
Comments to the Pennsylvania Public Utility Commission on the utilization of storage resources as electric distribution assets
Long-Term Planning to Support the Transition of New York’s Gas Utility Industry
Synapse provides technical and policy support for the Rhode Island Division of Public Utilities and Carriers on a range of topics including renewable energy, power sector transformation, performance incentive mechanisms, rate and bill impacts, grid modernization, beneficial electrification, and cost-effectiveness testing. This work includes supporting the Division with all aspects of energy efficiency program design, review, and implementation. The work also includes conducting research and analysis on renewable energy programs in Rhode Island.
In 2020 and early 2021, the Rhode Island Division of Public Utilities and Carries engaged Synapse to prepare two reports. The first estimates the costs and benefits of the Rhode Island Community Remote Net Metering Program and the Community Remote Distributed Generation program using the Rhode Island benefit-cost test. The second estimates the macroeconomic impacts of the program including job creation, personal income, business income, state tax revenue, and stage gross domestic product.
Macroeconomic Impacts of the Rhode Island Community Remote Net Metering Program
Synapse prepared and sponsored expert witness testimony on issues related to the investor-owned utilities’ plans for their low-income energy efficiency programs (called the “Energy Savings Assistance Program” or "ESA") for the 2021-2026 period. The testimony made recommendations regarding program goals, depth of savings, cost effectiveness, addressing the mobile home segment, consideration of health and safety measures, review of pilot proposals, and consideration of long-lived fossil-fuel burning equipment. Synapse also participated in workshops and provided technical support with comments on the draft and final proposals of the Staff of the California Public Utilities Commission Energy Division, which set forth a vision and framework for the ESA program to ensure that participants realize greater energy bill savings.
Comments of The Utility Reform Network on the Energy Division Staff Proposal and Utility Applications
On behalf of the Office of the People's Counsel for the District of Columbia, Synapse performed a Ward-level analysis of three future solar scenarios for the 2019-2041 timeframe. Using geospatial and economic analysis, Synapse also calculated the likely mix of private and community solar for the District, as well as the likely mix of rooftop, parking lot, and ground-mount solar through the study period. Based on the scenarios developed, Synapse recommended courses of action to help the District meet its ambitious solar carve-out goal (10% in-District solar by 2041). Finally, Synapse conducted a rate impact assessment of each solar scenario to determine which has the best impact on ratepayers in the District. Synapse recommended the District government closely monitor progress of the solar installations relative to the carve-out, as benefits are greatest if compliance is achieved early in the study period.
Tucson Electric Power (TEP) filed a rate case with the Arizona Corporation Commission requesting approval to place into rate base its purchase of the Gila River Unit 2 natural gas combined cycle plant and its investments in ten new reciprocating internal combustion engine (RICE) units. Synapse experts Avi Allison and Devi Glick filed testimony on behalf of Sierra Club evaluating the prudence of these purchases and assessing the economics of TEP's remaining coal units.
Surrebuttal Testimony of Avi Allison in Docket No. E-01933A-19-0028
Response to Late-filed ACC Staff Testimony of Devi Glick in Docket No. E-01933A-19-0028
On behalf of the Maryland Office of the People's Counsel, Synapse is providing technical support and expert witness services in order to facilitate alternative ratemaking proceedings, with a focus on multi-year rate plans.
On behalf of the District of Columbia Department of Energy and Environment (DOEE), Synapse provided expert witness testimony regarding Pepco’s proposed multi-year rate plan and performance incentive mechanisms. Synapse also drafted comments in response to the Commission's Notice of Inquiry regarding implementation of the CleanEnergy DC Omnibus Amendment Act of 2018, which requires the Commission to consider the “effects on global climate change and the District’s public climate commitments.”
GD2019 04 M: DC DOEE Comments Responding to Notice of Inquiry
Direct Testimony of Courtney Lane in Formal Case No. 1156
Rebuttal Testimony of Courtney Lane in Formal Case No. 1156
Surrebuttal Testimony of Courtney Lane in Formal Case No. 1156
Supplemental Testimony of Courtney Lane in Formal Case No. 1156
On behalf of Earthjustice, Synapse reviewed the U.S. EPA's benefit-cost analysis of changes to the proposed power plant effluent limitations guidelines (ELG). Synapse created an expert report that Earthjustice submitted as part of its official comments on the proposed rule modification.
The purpose of this report is to (1) evaluate the proposed changes to the 2015 ELG rule; (2) review the four options the EPA lays out for compliance (focusing on Options 2 and 4); (3) review the EPA’s benefit cost analysis (BCA); (4) critique the EPA’s analysis and results; and (5) provide recommendations on how the EPA should structure its BCA and which compliance option it should recommend.
Synapse prepared a Technical Brief that provides an overview of benefit-cost analysis techniques for reviewing utility proposals for grid modernization investments. The Brief is written for regulators, consumer advocates, and other stakeholders who seek to determine whether grid modernization proposals are in the public interest; especially proposals for utility-facing technologies that help advance reliability, resilience, advanced metering, and the integration of distributed energy resources. The Technical Brief addresses some of the most challenging aspects of benefit-cost analysis for grid modernization, such as determining the appropriate cost-effectiveness test to use, accounting for interactive effects between grid modernization components, and accounting for qualitative benefits. Tim Woolf presented the material in a training course for consumer advocates at the meeting of National Association of Utility Consumer Advocates in November 2018. He also presented the material at the Mid-Atlantic Distribution Systems and Planning Training with the NARUC-NASEO Task Force on Comprehensive Electricity Planning on March 8, 2019. The technical brief was published in February 2021.
Benefit-Cost Analysis for Utility-Facing Grid Modernization Investments
Electrification of the transportation sector is imminent, offering promises of lower costs for both electricity consumers and vehicle owners, but the path and speed the transition takes is not predetermined. The costs and benefits of electric vehicle (EV) adoption and the manner in which those costs and benefits are allocated among utility customers can vary substantially, with important implications for equity. The costs to utility customers are largely driven by the timing of EV charging, as well as any utility transportation electrification programs that rely on ratepayer funds. Who experiences the benefits depends, in part, on the design of transportation electrification programs, although many benefits (such as rate reductions and reduced pollutants) will be experienced by all utility customers.
Synapse worked with an advisory group composed of consumer advocates from across the country to develop a framework for helping consumer advocates analyze EV policy options (including ratepayer-funded transportation electrification programs) and ensure that the benefits of EV adoption are equitably distributed across customers.
Tampa Electric Company (TECO) filed an application to construct a new 1090 MW gas-fired power plant at a cost of $895 million. This so called “modernization” project sought to repower an existing steam turbine at the site of the coal- and gas-fired power plant at the Big Bend Power Station in Tampa, Florida. Synapse provided analysis and expert testimony on behalf of the Sierra Club to evaluate the need for, and impact of, the proposed plant.
Synapse found that TECO's application did not demonstrate a need for the electricity generated by this new gas plant, and made numerous dubious claims about the project’s environmental and economic benefits. Witness Bruce Biewald submitted testimony on the climate damages that will result from the construction of the gas plant. Witness Devi Glick submitted testimony assessing the electrical energy needs of TECO’s customers, and identifying ways to meet those needs through better system planning and cleaner, lower cost alternative resources.
The Proposed Plant at Big Bend: A Review of Climate Impacts
Bloom Energy (Bloom) required consulting services and technical assistance to help it meet its short‐ and mid‐term goals for the incorporation of its Energy Server Platform fuel cell product into various energy efficiency programs in the United States, with an immediate focus on Massachusetts. Bloom’s fuel cell is unique as it produces electricity at higher efficiencies than that generated by natural gas combustion turbines or other typical fuel cell technologies. The result is cost savings for customers and reduced carbon emissions for states.
On behalf of Bloom, Synapse Energy Economics developed a whitepaper to introduce this product to energy efficiency Program Administrators more generally, and a Massachusetts-specific cost‐effectiveness brief based on state-specific cost-effectiveness modeling. Our analysis found that the technology is cost-effective using the Massachusetts energy efficiency cost-effectiveness framework with a benefit-cost ratio greater than one, assuming a reasonable measure life. We also calculated the impact of including avoided health cost benefits on the benefit-cost ratio.
All-Electric Solid Oxide Fuel Cells as an Energy Efficiency Measure
Synapse performed a study to examine opportunities for, barriers to, and economic impacts of energy storage deployment in the context of Colorado’s changing energy landscape. The resulting report discussed: storage’s role in meeting clean energy targets; existing facilities, industries, and legislation related to storage; available commercial technologies and their services to the grid; state barriers and example solutions from other states; and the impact of various policy scenarios on the energy storage in Colorado's future, based on electric system modeling results.
On behalf of Sierra Club, Synapse reviewed and critiqued the DSM Programs proposed by the Virginia Electric and Power Company (Dominion). Our testimony focuses on how well the proposed DSM programs comply with statutory and regulatory requirements, the proposed DSM program spending and savings levels, DSM cost-effectiveness, and DSM program design. Virginia’s Grid Transformation and Security Act requires Dominion to spend $870 million on energy efficiency between 2018 and 2021. The Company only proposed a budget of $262 million for its 2019-2023 DSM programs, which includes lost revenues. We argue the Company should increase its budgets and remove lost revenues from that budget to meet the statutory budget requirement. Based on the Company's potential study and energy efficiency program efforts in other states, there are plenty of savings available with an increased budget. The cost-effectiveness screening practices in Virginia could also be improved, including to account for all costs and benefits in each of the tests used in the state, and to evaluate rate and bill impacts more comprehensively than relying on the Rate Impact Measure test.
On behalf of the North Carolina Sustainable Business Association, Synapse modeled two scenarios: a "Duke IRP" scenario, which included the Company's planned retirements and additions of more than 9 GW of new gas capacity, and a "Clean Energy" scenario, which included increased penetrations of solar and battery storage technologies. We compared these two scenarios based on energy, capacity, emissions, and impacts to health, rates/bills, GDP, and jobs in North Carolina. Synapse also examined the same impacts for ratepayers in South Carolina on behalf of the South Carolina Solar Business Alliance. The Synapse analyses found that renewable and battery resource options are comparably cost-effective to new natural gas for Carolina ratepayers, and offer other benefits as well.
Modeling Clean Energy for South Carolina: An Alternative to Duke's Integrated Resource Plan
The late January 2019 Polar Vortex weather event brought extreme temperatures to the upper Midwest through New England – the same stretch of the country where the most fossil fuels are used to heat buildings. As it becomes clear that a decarbonized electric grid is possible, “#ElectrifyEverything” has become a rallying cry for the path to transportation and building decarbonization. In this webinar, we explore the hypothetical: What if all the buildings from the Dakotas, to the Ohio River Valley, through Maine were heated with cold climate heat pumps instead? We estimate the impact on hourly peak electric loads, and we use this to tee up and discuss questions about what a cost-effective plan to decarbonize these buildings would need to address.
As a continuation of previous work, Synapse provided counsel to the NS UARB with technical consulting services on demand side management (DSM) issues. As part of the project, Alice Napoleon submitted evidence on EfficiencyOne?s proposed 2020-2022 Demand Side Management Resource Plan. In addition, Synapse reviewed, conducted analysis, and provided comments on the following issues: improving the accuracy of energy savings and spending projections; modeling DSM rate and bill impacts; assessing DSM potential in the province; designing a program to target DSM at locations where distribution system investment can be avoided; and modeling avoided transmission and distribution system costs.
Synapse Comments on EfficiencyOne Performance Alignment Study - M09096
Synapse Comments on EfficiencyOne's 2019 Rate and Bill Impact Analysis and Model - M09471
Since 2007, Synapse has assisted the Cape Light Compact with various aspects of their participation in the New England Forward Capacity Market (FCM).
A new report produced by Synapse Energy Economics, the Regulatory Assistance Project, and Community Action Partnership—with support from the Robert Wood Johnson Foundation—takes an in-depth look at the disparate impacts electric and natural gas infrastructure have on economic, social, and health outcomes—and consider how to ensure that a clean-energy future is a more equitable future. The report finds a variety of opportunities for policymakers, including policies to make energy more affordable for vulnerable communities, expand access to energy, reduce environmental hazards, and create jobs in the clean energy transition. The report also includes case studies from municipalities, states, and regions across the country that are working to achieve these goals. The small city of Bloomfield, Iowa, has taken charge of its energy future, transforming its approach to resource planning, investing in efficiency and solar power, and spurring local development. In Ohio, a statewide arrearage management program provides a model for protecting customers from utility shutoffs. In Minnesota, Xcel Energy and the state’s utility regulators are working together to implement performance-based regulation, with benchmarks for improving customer service quality and workforce diversity. And the 10 northeastern states that participate in the Regional Greenhouse Gas Initiative are reducing carbon dioxide emissions (and other pollution) from power plants, improving environmental conditions and community health outcomes. This report highlights these successes and provides policymakers with insights into how to create a successful – and economically inclusive – transition to a clean energy future.
For further insights on this report, read our blog post here.
On behalf of the Sierra Club, Erin Camp, PhD wrote expert witness testimony evaluating Dominion Energy’s electric vehicle (EV) Smart Charging Infrastructure Pilot Program (“Pilot Program”), focusing on the light-duty EV stock growth projection for Dominion’s service territory. The EV stock growth projection, which was used to calculate the number of EV charging stations eligible for rebates in the Pilot Program, underestimated the likely adoption of light-duty EVs in the Company’s service territory. Dr. Camp’s analysis found that, by 2030, the number of registered EVs in the Dominion’s service territory is likely to be double what was predicted by the utility. Her testimony encouraged the utility to recalculate the forecasted EV market and to update the estimated number of required EV charging stations. Dr. Camp also explained that encouraging EV adoption with a well-designed utility program can put downward pressure on rates and benefit all consumers in Dominion’s service territory. Further, a well-designed program will also ensure that the benefits of transportation electrification are equitably distributed to all customers, including low- and moderate-income customers, by improving access to clean, electric transportation options in the form of electric transit (i.e., buses) and charging stations to support EV charging at multi-family buildings.
Earlier Synapse work on EV Rates, completed on behalf of NRDC, can be found here.
Electric Vehicles are Driving Electric Rates Down - June 2019 Update
The electrification of transportation systems can bring substantial economic and public health benefits. Synapse’s new guidebook for consumer advocates describes how to evaluate the potential impacts of EVs on customers’ electricity rates, health, and vehicle expenditures. It also describes some of the policies that can be implemented to help ensure that transportation electrification occurs in a manner that allows all customers, particularly low-income and other vulnerable groups, to share in the benefits while not unfairly bearing the costs.
Synapse's Ben Havumaki and Tim Woolf lead an afternoon conversation about grid modernization that both addresses broad themes and zooms into the nitty gritty. Topics include:
- Overview of key concepts in grid mod
- Benefit-cost analysis, including how to select an appropriate cost test for grid mod projects
- Challenges in quantifying costs and benefits
- Customer equity
- Best practices
- Case studies of recent utility-facing grid modernization plans
Sierra Club retained Synapse to conduct an updated economic analysis of the J.K. Spruce coal plant, located near San Antonio, Texas. Synapse evaluated the recent economic performance of the plant, the likely performance of the plant over the next two decades, and the availability of cost-effective renewable alternatives to Spruce. Synapse found that (1) the Spruce plant likely lost more than $100 million relative to the market between 2013 and 2018; (2) Spruce is likely to continue to lose money relative to the market in the near term; (3) Spruce will only become profitable relative to the market over the long term if a series of favorable conditions hold; (4) CPS would likely save money by replacing the Spruce plant with renewable resources, even under market conditions favorable to the Spruce units; (5) replacing Spruce with renewables would reduce emissions and associated regulatory risks in addition to likely reducing costs; (6) retiring uneconomic coal units would be unlikely to harm CPS's credit rating; and (7) the current planned Spruce retirement dates are not based in a sufficiently robust and transparent planning process. We concluded that CPS should promptly engage in a thorough, public planning process to evaluate the potential near-term retirement of the Spruce units.
Synapse worked on behalf of Labor Network for Sustainability to analyze the economic benefits of improving energy, water, and transportation infrastructure in Massachusetts through increased state, municipal, and public investment. First, we identified spending gaps between existing investment plans for these three sectors and the level of investment needed to bring the sectors to a state of good repair. We used infrastructure needs reports, gap analysis studies, and state policy goals to identify the spending gaps. Next, we calculated the employment impacts of improving this infrastructure through increased investment between 2020 and 2030. We used IMPLAN, an industry-standard job impact model, to convert annual spending levels into annual job creation. We produced a final report summarizing the results for all three sectors as well as a selected set of city-specific case studies.
On behalf of Sierra Club, Synapse developed a least-cost resource portfolio to inform future plans for the Santee Cooper public utility in South Carolina. The resulting report explores a variety of energy mixes for the state-owned utility, and demonstrates that Santee Cooper’s continued reliance on coal or building large fracked-gas plants would be the costliest options. The least-cost option entails a combination of renewable energy resources and energy efficiency.
On behalf of Maine Renewable Energy Association and other Maine stakeholders, Synapse partnered with Sustainable Energy Advantage to assess the impacts of expanding Maine’s Class I renewable portfolio standard (RPS) to reach 50 percent by 2030. This analysis found that expanding the RPS would: Create 170 jobs per year between 2020 and 2030; Improve public health by curbing air pollution, avoiding $500,000 per year in public health damages between 2020 and 2030; Add 700 MW of new, in-state renewable energy projects; Result in minimal impact to Maine’s ratepayers, with only slight increases in residential bills of $1.16 to $1.76 per month between 2020 and 2030; and Reduce Maine’s reliance on fossil fuels by 5% and curb greenhouse-gas emissions from the electric sector attributable to Maine by 55%.
Maine RPS Analysis Appendix
Burlington, Vermont’s municipal electric utility, Burlington Electric Department (BED) contracted Synapse and Resource Systems Group (RSG) to develop a roadmap on how the city could best achieve its Net Zero Energy by 2030 goal. The City’s goal is defined as reducing and eventually eliminating fossil fuel use from its heating and ground transportation sectors.
This roadmap is a strategic analysis of the major steps or milestones needed to reach the City's Net Zero by 2030 goal with supporting data and recommendations for next steps. In order to develop this roadmap, the Synapse/RSG team:
- developed a 2018 baseline of energy use across all sectors
- projected a business-as-usual trajectory through 2030
- analyzed four pathways to net-zero energy by 2030, including the magnitude and cost-effectiveness of each opportunity
- detailed a host of policies and strategies with consideration for impact, cost-effectiveness and equity
The intended audience for this roadmap is implementers of climate action goals, strategies and policies nationwide: including community and state leaders, partner organizations, utilities, and community members. The approach and supporting strategies are applicable to many communities nationwide. The roadmap is publically available and can be viewed here.
In early 2021, Synapse was contracted by BED to update GHG emissions and other decarbonization metrics for Burlington in order to compare actual progress in 2019 and 2020 to the projections modeled in the Net Zero Energy Roadmap. This analysis showed that Burlington's emissions have fallen 15 percent since 2018, in line with a Net Zero trajectory. The COVID-19 pandemic contributed significantly to emissions reductions in 2020, particularly by reducing the number of miles driven in private vehicles. Burlington now has the opportunity to double down on decarbonization measures, including the electrification of transportation and heating, to mitigate any post-pandemic emissions rebound.
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