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.
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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.
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
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 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 conducted analysis and provided comments on proposals to modify the DSM rate and bill impact model, to develop a methodology for calculating avoided transmission and distribution system costs, and to design a program to target DSM at locations where distribution system investment can be avoided. Synapse also analyzed and critiqued a DSM potential study, and an analysis of potential bias in the program administrator's projections of energy savings and spending.
Synapse Comments on EfficiencyOne Performance Alignment Study - M09096
Synapse Comments on EfficiencyOne's 2019 Rate and Bill Impact Analysis and Model - M09471
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 with Synapse Energy Economics (Synapse) and Resource Systems Group (RSG) to develop a roadmap to provide clarity and insight into how the City could best achieve its Net Zero Energy by 2030 goal. The City’s Net Zero Energy goal is defined as reducing and eventually eliminating fossil fuel use from the heating and ground transportation sectors. Burlington currently sources 100 percent of the City’s electricity needs from renewables. Burlington’s Net Zero Energy goal is the most ambitious climate goal established by any community in the United States to date for both its rapidity and comprehensiveness.
This roadmap is a strategic analysis of the major steps or milestones needed to reach the goal with supporting data and recommended next steps for achieving the goal. 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; and,
- 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. Policymakers, implementers, and citizens in states, regions, cities, and towns can read the roadmap here.
The New Brunswick Energy and Utilities Board Staff commissioned Synapse to review New Brunswick Power Corporation’s Advanced Metering Infrastructure Capital Project proposal. Synapse reviewed, critiqued, and made recommendations to The Board regarding NB Power’s proposal, identifying multiple concerns within the proposal including its use of outdated Advanced Metering Infrastructure (AMI) technology and features assumptions, a lack of considering alternative scenarios such as a partial rollout, and potentially overstated savings and benefits, and understated costs of investments.
Synapse worked with New Hampshire's Benefit/Cost Working Group to develop an energy efficiency cost-effectiveness framework that is intended to fully reflect state energy policy goals. Synapse and the working group applied the seven steps framework of the National Standard Practice Manual to develop the new framework for New Hampshire. Synapse recommends New Hampshire utilities adopt the Granite State Test as the primary cost-effectiveness test for energy efficiency resources, and review the results of a secondary Granite State Test as well as the Utility Cost Test when assessing program cost-effectiveness.
Synapse provided expert advice on and analysis of energy efficiency programs offered by New Jersey's Clean Energy Program for the New Jersey Division of Rate Counsel. We reviewed, analyzed, and commented on various energy efficiency-related matters, including the state-administered programs’ designs and budgets, avoided energy supply cost estimates, cost-benefit analyses, energy savings protocols updates, and fiscal year budget proposals. We also reviewed and commented on New Jersey Energy Master Plans, a three-year energy efficiency program plan called the Comprehensive Resource Analysis, and various proposals associated with the new energy efficiency program framework including program delivery structure, program design, performance incentives, and cost recovery.
On behalf of the Environmental Defense Fund, Synapse conducted a benefit-cost analysis of a regulation to curb methane emissions from the oil and gas industry in New Mexico. The analysis evaluated the Gold Standard set of emissions regulations, comparing implementation costs to several types of benefits to the state of New Mexico: sales from newly captured gas, avoided costs related to human health impacts, and avoided nonattainment costs of reduced GHG emissions. Additionally, the report evaluated the global societal benefit of reducing methane emissions into the atmosphere.
Synapse prepared testimony on energy efficiency targets and incentives on behalf of the Natural Resources Defense Council in the recent Con Edison rate case. The testimony addressed the need to develop electricity and gas efficiency savings targets that are consistent with the Commission's statewide targets as well as the state's carbon emission reduction goals. It also addressed the need to provide sufficient budget to allow the utilities to provide the efficiency services necessary to meet the targets. Synapse also recommended modifications to the utility's cost-effectiveness practices to be consistent with the Commission's recent order on Benefit-Cost Analyses and to ensure the implementation of all cost-effective efficiency resources. Finally, the testimony addressed the energy efficiency earning adjustment mechanisms (i.e., performance incentive mechanisms) to ensure that Con Edison has sufficient incentive to implement effective efficiency programs, but not overlapping or unduly excessive incentives.
Comments on Comprehensive Energy Efficiency Initiative Case 18-M-0084
On behalf of the Clean Energy Parties, Synapse reviewed each of the New York utilities’ marginal cost of service studies and supporting data used to determine the distribution system value provided by distributed solar (expressed as Demand Reduction Value and Locational System Relief Value). Based on our review and analysis, Synapse developed a set of recommendations intended to create consistent and reliable methodologies for determining the costs avoided by distributed energy resources across New York State.
CEP Comments on Future of Value Stack
Climate Costs and the "Value of E": Incorporating the costs of carbon emissions into New York's electric system planning
Washington D.C. is experiencing rapid development of new residential and office buildings in and around the Mt. Vernon Triangle area. In response, the local utility has proposed building a new substation to serve the expected load growth at a cost of approximately $150 million. The utility reviewed and incorporated some energy efficiency and other distributed energy resources (DER) in its load forecast, but concluded that such non-wires solutions (NWAs) do not provide enough capacity to resolve the expected distribution constraints. However, Synapse Energy Economics’ analysis revealed that the utility’s plan did not adequately account for the potential impacts of cost-effective targeted DER solutions or future building codes.
Synapse conducted a comprehensive assessment of the utility’s load forecast and the feasibility of NWAs. We quantified cost-effective NWAs sufficient for deferring the need for the substation. This presentation highlights the key issues, assumptions, methodologies, and results from our analysis. Further, we present how our findings can be applied to other regions facing similar situations. Specifically, this presentation covers: (a) peak load forecasting methodologies; (b) peak load assumptions for existing buildings and new construction; (c) solar PV projections; and (d) achievable energy efficiency and demand response potential for the Mt. Vernon area. Synapse used building load data, existing end-use level potential studies, and program performance from leading programs to estimate energy efficiency and demand response potential. The presenter will also highlight studies and leading programs Synapse referenced to develop key assumptions on energy savings, costs, and participation rates.
Consulted on issues concerning utility rate proposals that seek to establish incentives to create non-wires alternatives to transmission and distribution investments.
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