Sierra Club retained Synapse to assess the 2017 Integrated Resource Pan (IRP) filed by Puget Sound Energy (PSE). Synapse's review found that the PSE IRP included a reasonable near-term resource plan but contained proposed actions that could lead to an unjustified deviation from that resource plan. In addition, Synapse identified a series of unjustified assumptions and conclusions regarding renewable resource costs and availability and coal plant retirement dates that resulted in a biased long-term resource plan. In comments submitted to the Washington Utilities and Transportation Commission, Synapse recommended that the Commission ensure full oversight of PSE's upcoming resource procurement processes and require PSE to use updated assumptions and enable full stakeholder participation in future IRP cycles.
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Rappahannock Electric Cooperative (REC) has requested approval to increase its fixed access charges for residential customers (from $10 to $20) and small commercial customers (from $28 to $37). Sierra Club retained Synapse to develop testimony that establishes how these increases in fixed charges are inconsistent with fundamental ratemaking principles. In testimony before the Virginia State Corporation Commission, Melissa Whited addressed how the increases would provide inefficient prices signals, reduce customer equity, and reduce incentives for investments in distributed energy resources. Ms. Whited also recommended alternative methods REC could employ to address concerns about revenue sufficiency.
California’s ambitious state law SB 350 aims to increase renewable energy generation and achieve “widespread transportation electrification” across the state. Pursuant to this law, California’s largest investor-owned utilities are proposing to make over $1 billion in transportation electrification investments. These investments are accompanied by new rate designs to support adoption of electric vehicles (EVs) and encourage charging in a manner that is consistent with electrical grid conditions. Synapse was retained by NRDC to evaluate the utilities’ rate design proposals for public fast-charging facilities, commercial fleets, and residential customers.
You can find more recent Synapse work focusing on EV rates, completed on behalf of NRDC, here.
Testimony of Melissa Whited on Commercial EV Rates
Testimony of Melissa Whited on Fast Charging Infrastructure and Rates
Testimony of Melissa Whited on Residential Rates
Rebuttal Testimony of Melissa Whited on EV Rate Design
Electric Vehicles are Not Crashing the Grid
Synapse analyzed the implications of higher fixed charges, time-of-use rates, and minimum bills on customers of Maryland's electric cooperatives. The study focused on the ways that these rate designs would impact low-income customers, low-usage customers, net metering customers, and the ability for Maryland to achieve its energy efficiency goals. This analysis was in response to Maryland Senate Bill 1131, which would have required the Maryland Public Service Commission to approve increases to electric cooperative customers' fixed monthly charges.
In support of New York State’s nation-leading GHG emissions reduction goals—targeting 40 percent reduction of GHG emissions by 2030 and 80 percent by 2050—the New York State Energy Research and Development Authority (NYSERDA) has begun a process of developing an integrated policy framework to address emissions from the heating and cooling sector. Synapse joined a group of consultants led by Meister Consultants to assist NYSERDA with this effort. More specifically, Synapse assisted NYSERDA and Meister with developing (a) a comprehensive database of costs and performance of Renewable Heating and Cooling (RH&C) technologies such as air-source heat pumps, geothermal heat pumps, solar hot water, and heat pump water heaters; (b) an Excel-based tool to analyze costs and benefits of RH&C technologies; and (c) a state RH&C Policy Framework report. As part of our effort to develop RH&C technology profiles, Synapse also participated in a stakeholder meeting by the Advisory Committee of industry stakeholders and experts and facilitated a working group on air-source heat pumps.
In 2016, Public Service Company of Colorado (PSCo) filed a request for rate design modifications, including a tiered monthly “Grid Use Charge” for all residential customers and a voluntary residential demand – time-of-use rate. The Company’s stated intent for the proposed Grid Use Charge was to act as an interim step before the implementation of a demand charge. On behalf of Energy Outreach Colorado, Synapse conducted an analysis of PSCo’s proposal and Tim Woolf provided expert testimony before the Colorado Public Utilities Commission. Synapse’s testimony challenged the Company’s proposal to move residential customers toward demand charges because such charges are inconsistent with fundamental rate design principles, create inefficient price signals, are complex and difficult for residential customers to respond to, place undue burden on low-usage and low-income customers, and may ultimately increase long-term electricity costs. Project ongoing.
Synapse is providing the Maryland Office of People’s Counsel (OPC) with technical assistance and testimony in Case No. 9406 regarding Baltimore Gas and Electric Company’s (BGE) electric rate increase request to recover costs for smart grid implementation and other costs. The increase of approximately $135.2 million is intended to pay for implementation of advanced metering infrastructure and underground conduit costs in Baltimore. Synapse staff and subcontractor Nancy Brockway submitted testimony covering the benefit cost analysis of the advanced meter infrastructure investments and cyber-security/ privacy concerns associated with the implementation of advanced meter infrastructure investment across the BGE service territory.
Synapse reviewed New Brunswick Power's 2018/2019 General Rate Case application on behalf of the New Brunswick Energy and Utilities Board Staff.
The thermal energy sector, which relies primarily on fossil fuels, accounts for approximately one third of Rhode Island’s total energy consumption and total carbon emissions. By diversifying the thermal energy sector to increase use of low-carbon renewable heating and cooling technologies (e.g., air source heat pumps, ground source heat pumps, wood pellet heating, solar thermal), Rhode Island can make significant strides toward achieving greenhouse gas emission reduction goals while producing substantial economic benefits for the state. To meet these objectives, the Rhode Island Office of Energy Resources tasked Synapse and Meister Consultants Group with (a) analyzing policies and programs designed to grow the renewable thermal industry and (b) conducting a detailed market model of an alternative thermal sector energy future. This market model analyzed the cost-effectiveness, energy rate and bill impacts, local job impacts, and emission impacts of an alternative future in which Rhode Island achieves five percent renewable energy penetration by 2035.
Kenji Takahashi presented on "Rhode Island Renewable Thermal Market Strategy -- An Analysis of Energy, Environmental, Economic, Energy Bill, and Local Job Impacts of an Alternative Renewable Thermal Energy Future for Rhode Island" at 2017 Energy Efficiency in Domestic Appliances and Lighting Conference.
Synapse assisted the New Jersey Division of Rate Counsel in evaluating Rockland Electric Company’s (RECO) proposal for investments in advanced metering infrastructure (AMI). The company’s proposal seeks pre-approval to install approximately 73,880 advanced meters across its entire New Jersey service territory. RECO’s petition in a previous docket, which Synapse also evaluated, proposed AMI deployment for only a subset of customers. Tim Woolf submitted initial direct testimony to the New Jersey Board of Public Utilities arguing against pre-approval of AMI investments.
Indiana Michigan Company (I&M) submitted an application to the Indiana Utility Regulatory Commission seeking a certificate of public convenience and necessity to install Selective Catalytic Reduction at Rockport Power Plant Unit 2 near Rockport, Indiana. Synapse assessed the analysis conducted by American Electric Power Generating Services on behalf of I&M in support of the application. Specifically, Synapse examined if the installation of the controls would be in the interest of I&M’s ratepayers and if the proposal was consistent with regulatory requirements. On behalf of Citizens Action Coalition of Indiana, Sierra Club, and Valley Watch, Dr. Jeremy Fisher submitted testimony to the Commission recommending that the Commission deny the CPCN on the basis that the Company’s analysis is outdated and Rockport 2 is not a reasonable long-term resource.
Sierra Club retained Synapse to conduct an 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 the Spruce plant has likely lost more than $100 million relative to the market since 2015, is likely to lose another $100 million from 2017 to 2019, and will only become profitable over the long term if a series of favorable conditions hold. Synapse concluded that Spruce Unit 1 would be unlikely to recover the costs of a proposed new selective catalytic reduction (SCR) pollution control system, and that replacing Spruce with renewables would reduce emissions more comprehensively and cost-effectively than retrofitting Spruce with SCR.
On behalf of the Office of the People's Counsel, Synapse reviewed and assisted with comments regarding the proposed amendments to Chapter 40 District of Columbia Small Generator Interconnection Rules. Our review was informed by industry best practices and focused on whether the proposed modifications would streamline the interconnection process while maintaining the integrity of the distribution system.
2017 annual update of South Carolina Electric & Gas' (SCE&G) avoided costs, to be used in both PURPA QF rates and for Act 236 compliance. Witness Thomas Vitolo, PhD, submitted testimony (Docket No. 2017-2-E).
On behalf of the Northeast Energy Efficiency Partnerships, Synapse and Meister Consultants Group identified the opportunity, costs, and benefits available if strategic electrification is adopted as a key strategy for decarbonization in New York and New England. Dr. Hopkins, Kenji Takahashi, and Pat Knight are primary authors of the resulting report, Northeastern Regional Assessment of Strategic Electrification (July 2017), which characterizes the current markets for efficiency electrification technologies (such as heat pumps and electric vehicles), identifies policies to overcome market barriers, assesses the state of electrification technologies, and models the extent of electrification both possible given market dynamics and required to meet regional greenhouse gas emission goals.
Southwestern Electric Power Company (SWEPCO) filed a rate case with the Public Utilities Commission of Texas seeking rate recovery of emission control investments at its Dolet Hills, Flint Creek, Pirkey, and Welsh coal plants. SWEPCO also requested approval of changes to its rate design for net metering customers. Synapse assisted Sierra Club by conducting an economic analysis of (1) the modeling SWEPCO used to justify its emission control investments and (2) the rate and bill impacts of its proposed rate design change. Rachel Wilson filed testimony on behalf of Sierra Club addressing SWEPCO’s economic justification for the retrofits. Melissa Whited filed rebuttal testimony regarding SWEPCO’s proposed Distributed Renewable Generation tariff.
Cross-Rebuttal Testimony of Rachel Wilson Regarding SWEPCO Rate Recovery Application
Cross-Rebuttal Testimony of Melissa Whited Regarding SWEPCO Rate Recovery Application
Synapse provided technical and policy support for several aspects related to the NY REV Initiative. This included drafting detailed comments and reply comments on the New York Utilities' proposed Distribution System Implementation Plans, with an emphasis on ensuring that distributed energy resources are properly planned for and implemented. It also included a detailed review of NY energy efficiency activities and recommendations for how to promote the implementation of all cost-effective energy efficiency resources as part of the NY REV initiatives. This work also included technical support for estimates of avoided distribution costs at constrained locations on the grid; i.e., the "value of D."
You can find the Synapse report Gas Regulation for a Decarbonized New York, part of our support for NY REV, here.
Direct Testimony of Tim Woolf on CHGE Proposed EE EAM
The National Standard Practice Manual and the Value of Energy Efficiency in New York
A study of the relative costs of operating each of the four Dallman Units.
Sierra Club retained Synapse to review the input assumptions and modeling methodologies underlying the 2017 Integrated Resource Plans (IRP) filed by Arizona Public Service Company (APS) and Tucson Electric Power Company (TEP). In comments submitted on behalf of Sierra Club, Synapse presented evidence that APS's plan to build thousands of megawatts of new natural gas-fired capacity was based on a a series of analytical errors and flawed assumptions including an unrealistically high load forecast, under-statement of available cost-effective energy efficiency, inflated renewable costs, and deflated natural gas prices. Synapse recommended that APS hold off on procuring new gas capacity until it had produced an analysis containing a more reasonable set of assumptions. In comments on TEP's IRP, Synapse recommended that TEP revise its modeling to capture a wider range of scenarios and potential portfolios, and more rigorously assess the economic status of its coal units. Citing Synapse's comments, the Arizona Corporation Commission declined to acknowledge the IRPs submitted by APS and TEP, and imposed a series of requirements to ensure that future IRPs incorporate reasonable load-growth scenarios and evaluate a reasonable range of portfolios and sensitivities.
Initial comments on TEP 2017 IRP
Sierra Club Reply to Staff's Comments and Proposed Order
Southern Alliance for Clean Energy engaged Synapse to provide technical support regarding the Tennessee Valley Authority’s electricity rates. Synapse reviewed trends in electricity prices for industrial and residential customers to assess whether TVA allocates costs across customer classes fairly. Synapse published a white paper on our findings, "Electricity Prices in the Tennessee Valley: Are customers being treated fairly?"
Dr. Asa Hopkins provided testimony before the District of Columbia PSC on behalf of the DC Department of Energy and Environment. Altagas proposed to acquire the District’s gas distribution utility, and Dr. Hopkins testified regarding the suitability of Altagas as a purchaser in light of DC’s goals for greenhouse gas emissions reductions. His testimony included an analysis of the long-term potential for natural gas consumption in the District in the context of an 80 percent GHG emissions reduction across all sectors, and concluded that dramatic reductions in fossil fuel gas consumption are going to be necessary, that renewable natural gas supplies are unlikely to make up the difference, and that WGL would need to change aspects of its business model as the city moves toward its goals. Dr. Hopkins testified regarding the suitability of Altagas’s merger commitments to the District’s GHG goals in light of these conclusions.
Direct Testimony and Exhibits of Dr. Asa Hopkins Regarding Formal Case No. 1142
Jenn Kallay presented a Synapse paper entitled Opportunities to Ramp up Low-Income Energy Efficiency to Meet Climate Plan Goals at the 2016 ACEEE Summer Study on Energy Efficiency in Buildings conference. She discussed key findings and opportunities from the compilation of a dataset on low-income energy efficiency efforts in the United States.
Opportunities to Ramp Up Low-Income Energy Efficiency to Meet Climate Policy Goals (slide deck)
The DC Circuit Court of Appeals brought the Clean Power Plan back into the spotlight in May 2016, making the unusual move to hear the pending case in front of the entire nine-judge circuit. Synapse has highlighted the potential benefits of implementing the Clean Power Plan since its release last summer. During a webinar on May 26, 2016m Synapse Senior Associate Sarah Jackson and Kate Konschnik of Harvard Law School’s Environmental Policy Initiative discussed the outlook for the Clean Power Plan, including why planning continues for a low-carbon future and what some states and utilities have been up to since the Clean Power Plan was put on hold by the Supreme Court earlier this year.
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. Synapse’s analysis of the 2016 BGS Auction examined the price divergence observed between the PSE&G service territory and the other electric distribution companies. Synapse found that higher prices for the PSE&G territory are related to significantly high transmission charges compared to other New Jersey Electric Distribution Company utilities.
Synapse analyzed various options for an enhanced Renewable Portfolio Standard for Maryland, on behalf of the Maryland Climate Coalition. Using a Synapse-adapted version of the National Renewable Energy Laboratory’s Regional Energy Deployment System (ReEDS), we modeled three alternative options through the year 2030 to determine how Maryland could meet an expanded policy cost-effectively. The modeling found that the economic conditions surrounding wind and solar installations would allow the state to meet an expanded RPS in all scenarios analyzed. In addition, analysis showed that the emitting renewable resources currently included in the RPS—such as combustion of industrial by-products—had little impact on meeting RPS policies and were also only minimally affected by the policies themselves.
Enhancing Marylands RPS - Factsheet
Conservation Law Foundation retained Synapse to provide technical analysis related to the petition of Exelon for approval to construct and operate a 200 megawatt combustion turbine electric power generation facility in Medway, Massachusetts. Specifically, Synapse reviewed the modeling and testimony of Analysis Group regarding the proposed facility’s impact on compliance with the Massachusetts Global Warming Solutions Act.
Synapse provided expert technical consulting services to the New Jersey Division of Rate Counsel related to the Southern Company and AGL Resources petition seeking approval of the acquisition of AGL Resources by Southern Company. Synapse filed testimony addressing issues related to competition and market power.
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 developed a comprehensive framework for balancing the growth of distributed solar with customer protection. Rooted in fundamental ratemaking and long-term resource planning principles, this framework enables regulators, consumer advocates, and other stakeholders to assess the merits of distributed solar against its potential for inequitable cost-shifting from solar customers to non-solar customers. The framework is grounded in addressing the three key questions that regulators should ask regarding any potential distributed solar policy: (1) How will the policy affect the development of distributed solar? (2) How cost‐effective are distributed solar resources? and (3) To what extent does the policy mitigate or exacerbate any cost‐shifting to non‐solar customers? Answering these questions will enable decision‐makers to determine which policy options best balance the protection of customers with the promotion of cost‐effective distributed solar resources. This report describes the analyses that can be used to answer these questions.
In 2014-2015, Berkshire Gas in Massachusetts placed a moratorium on new services in part of its territory after identifying distribution capacity constraints and insufficient supply resources. On July 8, 2016, Berkshire Gas filed a petition with the Department of Public Utilities seeking approval of its Long-Range Forecast and Supply Plan (F&SL) under D.P.U. 16-103. The company based its plan on analysis of various resource options to increase access to natural gas for the region as a precursor to lifting the moratorium.
On behalf of the Town of Montague, Synapse reviewed and assessed the reasonableness of Berkshire Gas’s F&SL. Our review of the resource plan revealed that while the plan included energy efficiency and demand response as options, it gave little attention to such resources. Instead, the company recommended investment in extensive and expensive new infrastructure options. We concluded that the company could lift the moratorium by implementing a few simple steps: (a) re-establish curtailable agreements with two large customers that already have dual-fuel capability, and (b) change the way it estimates impacts from current and future energy efficiency programs. We also identified additional demand-side resource potential by analyzing the historical performance of gas energy efficiency programs in New England, current program offerings, and a new gas demand-response program based on internet-connected thermostats. Our analysis concluded that with these expanded demand-side resources, the company could expect future peak load to decline from today’s level over the next five years. Furthermore, the future load forecast could be even lower if it incorporated potential impacts from emerging technologies and other factors. Specifically, electric heat pumps and the state’s existing climate change policies are highly likely to lead to substantial electrification in various sectors and to lower overall gas consumption.
Using Demand-Side Resources to End a Moratorium on New Customers for a Local Natural Gas Company in Massachusetts
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