Synapse provided expert technical consulting services to the Maryland Office of the People's Counsel related to Exelon Corporation’s proposed acquisition of Pepco Holdings Incorporated. Specifically, Synapse reviewed the Joint Applicants' economic impact analysis and concerns regarding concentration of ownership, market power, and market manipulation in the wholesale electricity market. Synapse submitted testimony in the legal proceeding on behalf of the MD OPC. Synapse performed similar analysis related to the merger on behalf of clients in Delaware, New Jersey, and the District of Columbia.
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Direct Testimony of Paul Peterson on Market Power Issues Related to the Exelon-Pepco Merger in Maryland
Surrebuttal Testimony of Tyler Comings Regarding Economic Impact Analysis in Proposed Exelon-PHI Merger in Maryland
Surrebuttal Testimony of Paul Peterson on Market Power Issues Related to the Exelon-Pepco Merger in Maryland
Synapse provided expert technical consulting services to the New Jersey Division of Rate Counsel related to Exelon Corporation’s proposed acquisition of Pepco Holdings. Specifically, Synapse reviewed the Joint Applicants' economic impact analysis; merger-related reliability issues; and concerns regarding concentration of ownership, market power, and market manipulation. Synapse submitted testimony in the legal proceeding on behalf of the NJ DRC. Synapse performed similar analysis related to the merger on behalf of clients in Delaware, Maryland, and the District of Columbia.
Direct Testimony of Paul Peterson on Market Power Issues Related to the Exelon-Pepco Merger in New Jersey
Direct Testimony of Tyler Comings Regarding Economic Impact Analysis in Proposed Exelon-PHI Merger in New Jersey
The Center for Rural Affairs required technical assistance regarding the future of the Nebraska Public Power District (NPPD)‐owned Sheldon Station generating plant, including research, analysis, and findings presented in a report. Synapse detailed Sheldon’s future capital and operating costs and generation benefits, presented a list of credible options for NPPD’s replacement of Sheldon, and documented these findings in a clear, concise manner.
Synapse researched Sheldon’s future costs (i.e., costs driven by environmental regulation, market forces, and daily operations), as well as estimated the benefits NPPD gained by the plant’s operation, including those related to NPPD’s energy, capacity, and reliability needs. Synapse then outlined Nebraska‐specific options for alternatives, including energy efficiency, wind or solar photovoltaic generation, natural gas generation, market purchases, and/or transmission upgrades.
Synapse 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
In September 2014, Dominion Resources and its partners Duke Energy, Piedmont Natural Gas, and AGL Resources announced their joint investment in the 550‐mile interstate Atlantic Coast Pipeline (ACP). The proposed pipeline would bring natural gas from West Virginia through Virginia and into eastern North Carolina. Synapse reviewed two reports released by Dominion and its partners—one by ICF International and one by Chmura Economics & Analytics—that assessed the projected economic, job, and tax benefits associated with building and operating the ACP. Synapse identified a number of problems with the reports’ conclusions, finding that the ICF report likely overestimates the benefits of the pipeline and that both the ICF report and the Chmura report are largely inauditable.
Synapse staff developed pre-filed direct testimony for the Massachusetts Departments of Energy Resources and Environmental Protection related to the cost of Global Warming Solutions Act (GWSA) compliance avoided by energy efficiency programs in Massachusetts. Synapse developed a marginal abatement cost curve analysis examining the expected costs and reductions from specific policies. This methodology was used to explore the marginal policy—and associated cost—needed to achieve carbon dioxide emission reductions in line with the Massachusetts Global Warming Solutions Act.
Woolf Second Amended Direct Testimony Regarding the Avoided Costs of Complying with the Global Warming Solutions Act
Stanton Rebuttal Testimony Regarding the Avoided Costs of Complying with the Global Warming Solutions Act
Woolf Rebuttal Testimony Regarding the Avoided Costs of Complying with the Global Warming Solutions Act
Synapse prepared a report on the key institutional, regulatory, and market barriers to the expansion of wind and solar development in the near term. Despite the declining costs of these technologies, their expansion is limited by technical issues and by "virtual" inefficiencies—limitations associated with structures, communications, and procedures that have adapted in a localized, fossil fuel-centric power market. The Synapse report addresses transmission and other technical barriers, administrative burdens that stall development, uncertain renewable energy policies that weaken incentives, and rate design that negatively impacts distributed generation. The report also addresses supposed barriers such as threats to system stability from the addition of intermittent renewables that—it turns out—will not be an issue for many years.
Synapse reviewed a distributed solar tariff that was proposed as an alternative policy for the Town of Belmont, Massachusetts. At the request of a group of volunteer citizens, Synapse provided a memorandum that discussed a tariff proposed by the citizen group. The memo reviewed the alternative policy specifically to answer the following question: Is the tariff fair to ratepayers that do not have rooftop solar?
Synapse provided Utah Clean Energy with consulting services regarding a net energy metering (NEM) docket in Utah. Expert witness Tim Woolf testified before the Public Service Commission on an appropriate analytic framework to evaluate the costs and benefits of NEM. Specifically, Mr. Woolf discussed the need to apply two separate metrics: one to indicate cost impacts (in terms of present value of revenue requirements) and one to indicate rate impacts (in terms of the percent impact on rates).
Rebuttal Testimony of Tim Woolf on the Benefit-Cost Framework for Net Energy Metering in Utah
Surrebuttal Testimony of Tim Woolf on the Benefit-Cost Framework for Net Energy Metering in Utah
Synapse modeled various Clean Power Plan compliance options to determine how big an impact strong energy efficiency policies can have on the achievability and affordability of complying with EPA’s rule. Using the Synapse Clean Power Plan Toolkit, a collection of purpose-built in-house tools and commercial models, including the National Renewable Energy Laboratory’s Regional Energy Deployment System (ReEDS) model, Synapse examined the comparative cost of state implementation plans that maximize available energy efficiency strategies versus a future in which states are not Clean Power Plan‐compliant. Synapse modeled and found savings for each of the 48 continental U.S. states.
The results, updated in the factsheet and accompanying report below, show that if states comply using strategies that encourage cost‐effective energy efficiency, households can save on electricity bills.
Synapse held a series of public webinars on this topic:
- Bill Impacts of the Clean Power Plan Updated -March 17, 2016 View presentation here
- Bill Impacts of the Clean Power Plan - January 14, 2016 | 2 PM EST | View presentation here
- Bill Impacts of the Clean Power Plan (Repeated) - January 19, 2016 | 2 PM EST
Stopping the Clean Power Plan Raises Bills
Cutting Electric Bills with the Clean Power Plan Updated
The Clean Power Plan: Green and Affordable (factsheet)
Cutting Electric Bills with the Clean Power Plan
Cutting Electric Bills with the Clean Power Plan - January 15 Errata
Bill Impacts and the Clean Power Plan (webinar slides)
Synapse prepared two expert reports to be presented in annual property tax assessment cases relating to the valuation of the Byron Nuclear Power Station. The first gives a history of electricity restructuring, its effect on nuclear generation, and its impact on Illinois and the Byron station in particular. The second report rebuts the argument made by Concentric Energy Advisors that nuclear plants that are members of fleets enjoy superior historical performance due to this membership, and that the value of Byron station should thus be adjusted downward when assessing its worth to a non-fleet buyer.
Synapse and other supporting organizations—MassEnergy, Northeast Energy Efficiency Partnerships, and the Environment Economics & Society Institute—hosted a free, one-day training program for local environmental advocates interested in expanding their technical knowledge in order to become more effective intervenors and stakeholders.
Topics covered included the history and future of New England’s electric sector; supply and demand of energy in New England; the ISO and wholesale energy markets; current electric planning in New England; resource choices; and planning for greenhouse gas compliance.
Synapse assisted the Ohio Office of Consumer Counsel with issues related to EPA’s Clean Power Plan. This work included providing consultation and analysis on the plan’s costs to Ohio consumers, allowance trading, energy efficiency as a compliance option, and the impacts of compliance pathways on bills and emissions.
In 2013, Synapse performed an analysis for the Sustainable FERC Project examining the Eastern Interconnection Planning Collaborative (EIPC) process. The work included a more comprehensive summarization and interpretation of the costs and the benefits of the three modeled scenarios from Phase 2 of the EIPC analyses (1 – nationally implemented federal carbon constraint, 2 – regionally implemented national RPS, 3 – business as usual). Synapse's work addressed key issues not fully fleshed out in the EIPC reports. In 2015, the Union of Concerned Scientists retained Synapse to prepare a new report that synthesized the EIPC modeling results and Synapse’s analysis in the context of the Clean Power Plan.
Beyond the Clean Power Plan: Executive Summary
Synapse supported the National Association of State Utility Consumer Advocates and its members in addressing the EPA’s proposed Clean Power Plan in a manner that is cost-effective and efficient from an electricity consumer perspective.
Prior to the release of the rule, Synapse presented to NASUCA members key issues regarding the details of the proposed rule and the primary compliance options that may be available to states. Following the rule’s release, Synapse prepared a report focusing on the details of the rule as proposed. Recognizing that stakeholders have a wide range of reactions to the EPA’s Plan, the intent of the report is to be a common resource to help all of NASUCA’s members think through a broad range of potential implications of various compliance approaches to their respective consumers—whatever their individual state’s positions. Synapse presented on the findings of Implications of EPA’s Proposed “Clean Power Plan” at the 2014 NASUCA annual meeting in San Francisco, CA.
Synapse used its Clean Power Plan Planning Tool (CP3T) to perform multi-state analysis of the proposed rule to identify and explain a variety of challenges and opportunities related to multi-state compliance, including how states with dissimilar renewable technical potential, states with utilities that cross state boundaries, states with existing mechanisms for cooperation, etc., may approach regional compliance with the Clean Power Plan. Pat Knight, the lead developer of CP3T, provided a webinar for NASUCA members giving an overview of key issues surrounding the Clean Power Plan, as well as a walkthrough of CP3T’s multi-state functionality. Synapse also prepared a report presenting the results of the analysis, presented at the NASUCA 2015 Mid-Year Meeting.
As a third element of Synapse’s Clean Power Plan support to NASUCA members, Synapse prepared a report on best practices in planning for implementation of the Clean Power Plan. The report serves as a guide for consumer advocates to the logistics of developing a state implementation plan, with advice in areas such as stakeholder engagement, evaluating resource options, deciding on reasonable assumptions, identifying appropriate modeling tools, and selecting and implementing a plan.
This work was made possible by a grant from The Energy Foundation.
Best Practices in Planning for Clean Power Plan Compliance
Final Report: Implications of EPAs Proposed "Clean Power Plan"
Clean Power Plan: Key Issues for Consumers (slides)
Clean Power Plan: A Toolkit for State Compliance (slides)
Multi-State Compliance and CP3T (slides)
Comments on Best Practices Report and Multi-State Analysis (slides)
Best Practices in Clean Power Plan Planning (slides)
Multi-State Compliance with the Clean Power Plan in CP3T
Synapse 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)
Synapse prepared a series of briefs on the electric sector costs to consumers of low-emissions futures. The briefs are informed by modeling studies that investigate the costs of EPA’s Clean Power Plan, as well as a scenario in which we achieve low-cost emissions reductions even greater than those called for by the EPA.
Synapse used NREL's Regional Energy Deployment System (ReEDS) model to compare the costs of the U.S. electric sector transitioning to a Clean Energy Future with business‐as‐usual costs. In the Clean Energy Future, renewables grow rapidly to reach 70 percent of all generation by 2040, including nearly 200 GW of rooftop solar panels. Electricity sales are 25 percent lower than business-as-usual in 2040 as a result of savings from energy efficiency measures and standards, as well as demand response programs that pay participating consumers to curtail their energy use at times of peak demand. All coal-fired units built before 2005 are retired by 2040. This results in carbon dioxide emissions 84 percent lower than business-as-usual levels in 2040. Synapse found that consumers can save $41 billion in the year 2040 as compared to business as usual if states pursue these clean energy options.
The briefs and the associated background reports can be found below, along with recordings of webinars presenting the results.
Please note: Earlier versions of the publications found below reported 80-year lifetimes for nuclear units in both the reference and Clean Energy Future scenarios. In this analysis, nuclear power plants are actually assumed to retire after 60 years, after receiving one license extension from the Nuclear Regulatory Commission.
July 28 Webinar
September 3 Webinar
Clean Energy Future Technical Review: Brief #1 Background Report
Lower Costs Low Emissions Errata
Brief #2: Clean Power Means Lower Bills for Consumers
Bill Savings in a Clean Energy Future: Brief #2 Background Report
Bill Savings in a Clean Energy Future (July 28 Webinar Slides)
Understanding Clean Power Plan Compliance Paths
Brief #3: How Clean Power Will Save Us Money in the Long Run
Bill Savings in a Clean Energy Future, Part 2: Clean Power Plan Final Rule Update
Final Clean Power Plan: Modeling Costs to Consumers (September 3 webinar slides)
In a lengthy and complex legal proceeding, Entergy is contesting the New York state ruling that closed-cycle cooling is the best technology available for minimizing environmental impacts at Indian Point, and must be installed as a condition for renewal of state and federal operating licenses. Synapse assisted Riverkeeper in preparing for hearings, addressing the question of whether the costs of cooling towers at Indian Point would be "wholly disproportionate" to their benefits, and evaluating the implications of other New York regulations for Entergy's decisions about cooling technologies at Indian Point. Frank Ackerman testified in hearings.
Rebuttal Testimony of Frank Ackerman Regarding Permanent Fish Protection Outages at Indian Point Energy Center
Synapse critiqued industry claims that a small, sensible change in Food and Drug Administration (FDA) regulations will add billions of dollars to the costs of prescription drugs. Currently, generic drug producers are required to use exactly the same label and warnings as the brand-name version of the same drug; the Supreme Court has held that, as a result, the generic producers cannot be held liable for failure to warn their customers of known drug hazards if the warnings do not appear on the brand-name label. Generic drugs account for most prescriptions filled in the U.S., and brand-name production often ceases when generics enter the market. This often means that the brand-name label, and hence the identical generic labels, are no longer updated when new information is discovered about drug hazards.
FDA proposes to change its rules to allow generic drug producers to update their own labels. The drug industry claims this will cause huge increases in the cost of generic drugs. At the request of the American Association for Justice (AAJ, formerly the American Trial Lawyers Association), Synapse evaluated the costs and benefits of generic drug regulation, and critiqued industry arguments against the FDA rule change.
Synapse and Resource Insight assisted the Maryland Office of People’s Counsel in its evaluation of proposed metrics regarding price mitigation or Demand Reduction Induced Price Effects (DRIPE) in the context of the EmPOWER Maryland cases. The project team analyzed proposals and calculations presented to the Public Service Commission Working Group, and suggested revisions and alternatives as appropriate. Resource Insight’s Paul Chernick presented testimony to the Commission.
Synapse assisted a coalition led by PennFuture with its participation in an initial stakeholder meeting designed to provide feedback to the Pennsylvania Public Utility Commission and the statewide evaluator regarding a proposed design for a demand response program under PA Act 129. Synapse reviewed the scope of the Total Resource Cost test to be used to evaluate the program upon its completion. Project completed August 2014.
Synapse provided litigation support to the Department of Justice in United States v Duke Energy Corp, a case alleging that Duke Energy modified many of its coal-fired electricity units without obtaining the required New Source Review permitting as part of the Clean Air Act and without installing the required pollution controls. Synapse expert witness Bruce Biewald prepared an expert report analyzing PROMOD and similar modeling simulations prepared by Duke Energy and evaluating the anticipated impacts of the modifications on electricity generation. Mr. Biewald then provided assistance to the DOJ in preparation for trial.
As part of its plan to develop a 20 megawatt solar facility in Ludlow, Vermont, Ranger Solar commissioned Synapse to evaluate several aspects of the project’s impacts within the state of Vermont and the greater region. Synapse analyzed the energy and capacity needs of the state; the requirements of utilities in the region to obtain more renewable energy under state policies; and the extent to which the project meets those needs. Synapse also analyzed the project’s impact on economic activity in the state, wholesale markets, customer rates, and greenhouse gas emissions. In March 2017 Ranger Solar received regulatory approval to move forward with the project.
Direct Testimony of Thomas Vitolo on the Need and Economic Benefit of the Proposed Coolidge Solar Project
Synapse performed a feasibility study for Efficiency Maine Trust. The study analyzed the ISO-NE governing documents for real-time demand response and identified possible alternatives to ensure customers in Maine who are willing to provide demand response have the opportunity to do so.
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.
A key benefit of renewable energy is that electricity generated from new renewable resources displaces electricity generated from other types of power plants. In doing so, renewables reduce the consumption of fossil fuel and production of fossil fuel-related carbon dioxide emissions. In the Clean Power Plan originally proposed by EPA in June 2014, this effect was ignored when setting emissions targets for states: EPA’s formula omitted this effect. In the final version of the rule, released August 3, states’ targets do account for emissions displaced by renewable generation.
As part of our ongoing series of webinars on EPA’s Clean Power Plan, Synapse hosted a webinar on how displacement occurs within the electric power system, and what this means for final targets set by EPA as well as states’ compliance with the rule. Panelists included authors of the Synapse report Air Emissions Displacement by Energy Efficiency and Renewable Energy, a survey of evidence that renewable resources and energy efficiency have indeed displaced fossil fuel resources connected to the grid.
Synapse reviewed the incorporation of end-use components into the Nova Scotia load forecasting modeling.
Synapse CEO and founder Bruce Biewald presented on energy efficiency as a resource for compliance with EPA’s Clean Power Plan at the 2015 NASEO Energy Policy Outlook Conference in Washington, DC on February 5. His presentation, part of a panel on privately delivered energy efficiency, included a discussion of how analysis using Synapse’s Clean Power Plan Planning Tool can help to understand and estimate the benefits of energy efficiency as an element of state CPP compliance plans.
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