National Grid commissioned Synapse to develop a Microsoft Excel-based analytical model to assess the long-term rate and bill impacts of its Rhode Island energy efficiency natural gas programs. The model was designed to analyze annual and long-term rate and bill impacts from natural gas energy efficiency programs implemented over a course of three years. Synapse designed the model to analyze rate and bill impacts from natural gas energy efficiency programs in Rhode Island for four customer types: residential, income-eligible, small commercial, and large commercial and industrial (large C&I) and for each program contained within those categories. The model was designed for National Grid’s 2021–2023 Three-Year Energy Efficiency Program Plan and its 2021 Annual Program Plan, but it can be updated for subsequent prospective and retrospective analyses in assessing how the Plans meet the requirements for energy efficiency in Rhode Island.
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Synapse is providing expert testimony and analysis to support Sierra Club in Duke Energy Indiana’s Fuel Adjustment Cost (FAC) dockets for the period of September 2019 through May 2020.
Synapse is evaluating the unit commitment and dispatch practices for Duke’s four coal plants at Edwardsport, Cayuga, Gibson, and Gallagher as part of the Company’s regular Fuel Adjustment Cost Adjustment (FAC) dockets. We find that Duke has been uneconomically committing most of its units a majority of the time throughout this entire time period. These commitment and dispatch practices were further exacerbated by the Company’s implementation of a fuel price decrement in FAC 125 (March – May 2020) to address the Company’s coal oversupply.
We find that as a result of the Company’s uneconomic commitment and dispatch practices, Duke has accumulated net revenue losses (based on just variable and fuel costs) at most or all of its units during at least one (and in most cases all) of the FAC 123, FAC 124, and FAC 125 periods between September 2019 and May 2020. As a result of our work in FAC 123, the Indiana Utility Regulatory Commission agreed to open a subdocket to examine the issue of unit commitment more closely. Synapse has provided expert support and testimony in all three FAC periods as well as the subdocket.
Cause No. 38707-FAC123 Devi Glick Exhibits 1 through 5
Cause No. 38707-FAC123 Devi Glick Exhibits 6 and 7
Direct Testimony of Devi Glick in Cause No. 38707-FAC124
Cause No. 38707-FAC124 Devi Glick Exhibit 1
Cause No. 38707-FAC124 Devi Glick Exhibit 2
Cause No. 38707-FAC124 Devi Glick Exhibits 3 and 4
Direct Testimony of Devi Glick in Cause No. 38707-FAC125
Direct Testimony of Devi Glick in Cause No. 38707-FAC123 S1
Apogee Climate and Energy Transitions (Apogee) engaged Synapse to review the publicly available documents associated with the Kentucky Municipal Energy Agency's (KYMEA) 2020 Integrated Resource Plan. Synapse provided Apogee with a memo detailing its concerns with KYMEA's IRP and providing short, medium, and long-term recommendations. Dr. Thomas Vitolo summarized these findings and recommendations in a public comment at a KYMEA Board meeting on September 24, 2020.
Dr. Vitolo advised the KYMEA Board against further investments in fossil-fuel power plants or long-term contracts. He explained that the KYMEA has no need to invest in new power supplies until 2027 at the earliest and is fortunate that a 100-Megawatt coal contract is expiring in 2022, freeing KYMEA of the plant’s costs and risks. Dr. Vitolo also noted that KYMEA had an immediate opportunity to reduce its commitment to a natural gas peaking power contract with Paducah Power Systems, from 90 Megawatts to 30 Megawatts. He advised the KYMEA to actively pursue re-negotiating each of their existing power contracts in light of the much lower prices available in MISO. Lastly, Dr. Vitolo observed that for the medium and long-term perspectives, in-state solar power contracts are likely to provide low-cost, low-risk, and reliable energy to their customers.
Review of KYMEA's Integrated Resource Plan
On behalf of the Sierra Club, Synapse is providing expert comments and analysis in the Minnesota Public Utilities Commission’s investigation into the Self Scheduling and Self-Commitment practices of the state’s Coal-fired power plants.
In 2020, Synapse evaluated the unit commitment and dispatch practices of two Minnesota Utility companies: Minnesota Power’s two Boswell units and Otter Tail Power’s Big Stone and Coyote units.
Based on data and information submitted as part of the Companies’ 2020 Annual Compliance Filings, we found that both Otter Tail Power and Minnesota Power uneconomically self-committed and often appeared to have uneconomically self-scheduled their coal units throughout the 2020 reporting periods. Both utilities incurred significant losses (relative to the market price of energy) based on their unit commitment and dispatch decision-making processes. Otter Tail Power’s losses resulting from its commitment and dispatch practices were driven in large part by two factors:
(1) the Company’s decision to enter into a long-term fuel contract for Coyote at the mine that serves the plant (co-located with the mine) that designates a significant portion of its fuel costs as fixed costs; and
(2) the joint ownership structure and dual market operation of both the Big Stone and Coyote plants.
In 2021, Synapse evaluated Otter Tail Power’s units, focusing on the long-term coal contract and joint ownership structure issues outlined above. We evaluated the contract buy-out cost for Otter Tail Power to exit the coal contract at Coyote, and whether ratepayers would be better served by exiting the contract or continuing to operate the unit at a loss. We also reviewed actions the Company has taken to enable economic commitment at Big Stone, its plans to do the same at Coyote, and the challenges posed to attempting to implement fully economic operations based on the joint market and joint ownership at both plants.
Comments in Response to Otter Tail Power's 2020 Annual Compliance Filing
Surreply Comments in Response to Otter Tail Power's 2020 Annual Compliance Filing
Comments in Response to Minnesota Power's 2020 Annual Compliance Filing
Surreply Comments in Response to Minnesota Power's 2020 Annual Compliance Filing
On behalf of the Rhode Island Office of Energy Resources (OER), Synapse conducted a geospatial analysis to determine an estimate of the likely solar potential available within a number of solar siting categories. Synapse examined and quantified solar potential for the following six siting categories:
-Rooftop solar (including rooftops of residential single family, residential multifamily, commercial, industrial, municipal, and other building types)
-Ground-mounted solar in the following four categories: (1) Landfills, (2) gravel pits, (3) brownfields, and (4) commercial and industrial developed and undeveloped lots
-Parking lot / carport solar
We used geospatial analysis to examine the following types of potentials for each category of solar:
-Total Potential, an estimate of the solar potential for the entire area under consideration, with no exceptions.
-Technical Potential, an estimate of the potential excluding areas not suitable for solar development. These challenges may reduce technical potential, relative to total potential.
For residential rooftop solar, we also analyzed:
-Economic Potential, an estimate of the solar potential that is likely to be installed, given the current cost of the technology, the current financial incentives available, and the household economics specific to a municipality. This potential category was analyzed for residential rooftop solar only.
In addition, for each category of solar, we compiled estimates of these MW potentials translated into gigawatt-hour (GWh) generation potential, solar costs (based on costs available as of late 2019 / early 2020), avoided greenhouse gas emissions, and possible impacts on distribution system hosting capacity.
Solar Siting Opportunities for Rhode Island: Slide Deck
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.
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
Senate Bill 472: More Costly than Other Community Solar Options
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
Synapse was retained by the Sierra Club to evaluate the prudence of coal combustion residuals and effluent limitation guidelines retrofits at the Victor Daniel coal-fired power plant in Mississippi in light of ongoing and future costs and future environmental risk.
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.
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