On behalf of Counsel to the Nova Scotia Utility and Review Board (NSUARB), Synapse assessed Nova Scotia Power's (NSPI) advanced metering infrastructure pilot proposal. NSPI requested approval to deploy advanced (“smart”) meters to up to 1,000 customers at a cost of $8.2 million. Ms. Alice Napoleon identified multiple issues with the proposal, including, among other things, that the pilot period would neither provide sufficient time for data collection nor cover the period of highest system demand; that the pilot’s size was not adequately justified; that complementary programs to help customers experience the benefits from implementation of AMI were omitted; and that the proposed network for the pilot is not consistent with the network that may be required for full implementation. Ms. Napoleon concluded that the design of the proposed pilot would not provide a solid basis for determining whether the costs and benefits associated with AMI justify a full roll out. Ms. Napoleon recommended that NSUARB not approve the current pilot application based on the current record of evidence.
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Synapse provided analysis and expert testimony on behalf of Sierra Club in Oklahoma Gas & Electric’s application before the Oklahoma Corporation Commission seeking approval to install dry scrubbers at the Sooner generating facility. Synapse’s Tyler Comings evaluated the economic case for the retrofits with a focus on the assumptions used for natural gas price risk and fuel diversity. Mr. Coming’s testimony found that installing dry scrubbers at Sooner is not the least cost option. Mr. Comings recommended that the Commission deny the proposal. Should the Committee accept the proposal, Mr. Comings recommended it do so with conditions that would protect ratepayers.
Earlier testimonies from the Oklahoma Gas & Electric CPCN Proceedings can be found here.
Responsive Testimony of Tyler Comings on Oklahoma Gas and Electric Application for Approval to Install Dry Scrubbers at the Sooner Generating Facility
Synapse supported Delaware Riverkeeper in drafting comments to Federal Energy Regulatory Commission on the PennEast pipeline Draft Environmental Impact State, focused on the potential impacts on natural gas drilling in the state.
Delaware Riverkeeper's filed comments are available here.
On April 19, 2016, Potomac Electric Power Company (Pepco) requested approval for an electric rate increase of approximately $126.8 million to recover costs including, but not limited to, the implementation of advanced metering infrastructure (AMI) in its service territory. Maryland Office of People’s Counsel engaged Synapse to evaluate the assumptions and methodologies used by Pepco to determine the cost-effectiveness of its AMI deployment. Synapse’s analysis found that Pepco’s analysis overstated both the market-side and operational benefits of the AMI program. Max Chang submitted direct testimony to the Maryland Public Service Commission on behalf of Maryland OPC demonstrating that the program is essentially break-even and recommending that the Commission require Pepco to provide regular analyses of the program’s cost-effectiveness.
Lawrence Berkeley National Laboratory (LBNL) has prepared a series of technical reports on Future Electric Utility Regulation, which examine issues related to incremental and fundamental changes to electric industry regulation in a future with high distributed energy resource (DER) levels. Synapse provided research and analysis to support LBNL in producing a technical report on performance-based regulation in a high DER future. The report: summarizes the full suite of mechanisms used in various types of PBR; compares ratemaking and regulation of utilities under cost of service versus PBR paradigms; explains how to incorporate performance-based metrics focused on DER; presents key subtopics from the perspective of both the electric utility and the customer/broader public interest; describes a taxonomy of issues to consider in determining whether to implement some elements of PBR or comprehensive PBR; and describes criteria state utility commissions can consider to evaluate whether to adopt some form of PBR in the context of a high DER future.
Performance-Based Regulation in a High Distributed Energy Resources Future (webinar slides)
Synapse conducted a second supplementary audit of the operation of the Nova Scotia Power Inc. load retention tariff mechanism for Port Hawkesbury Paper pursuant to the Nova Scotia Utility and Review Board Decision Letter of May 23, 2014 in Docket M05803.
Kenji Takahashi presented "Progress and Prospect of U.S. Electricity Policies" at the Citizen's Alliance for Saving the Atmosphere and the Earth (CASA) seminar in Osaka, Japan on July 5, 2016. Presentation in Japanese.
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.
Synapse was retained by EPA to evaluate claims of petitioners seeking to stay the Regional Haze Rule Federal Implementation Plan (FIP) for Texas and Oklahoma. Dr. Jeremy Fisher and Mr. Bob Fagan provided declarations regarding the economic impact of the rule and the impact of the rule on transmission planning exercises within the ERCOT region.
OutSmart Power Systems provides commercial, industrial, and institutional facilities with a full energy optimization solution including its own cost-effective submetering, analytics on all circuit-level energy use transitions, and an energy services team focused on actionable, work order-ready efficiency improvement measures. On behalf of OutSmart, Synapse Energy Economics developed a cost-effectiveness screening tool and assessed the benefit-cost ratio (BCR) of OutSmart’s solution, providing program administrators in Massachusetts and others visibility into OutSmart’s cost effectiveness. Our analysis found that their solution is cost-effective with a benefit-cost ratio greater than one, assuming a reasonable measure life.
The Brayton Point Power Plant in Somerset, Massachusetts will retire by June of 2017, and give the town an opportunity to influence the fate of the 234-acre waterfront site. On behalf of a coalition of environmental advocates, Synapse has set the assessment in a regional context and reviewed several future options for the site to determine their pros and cons. Options analyzed included building a new natural gas plant on the site and installing a variety of clean energy generation and battery storage units – referred to as a Clean Energy Hub. The resulting report explores the impacts on the local economy in terms of jobs and tax revenues, the Commonwealth’s ability to comply with its Global Warming Solutions Act, and the perceived need for locally generated electricity.
Riverkeeper retained Synapse to assess the potential impacts to energy reliability and electric power sector air emissions associated with the construction and operation of a closed-cycle cooling system as the "best technology available" (BTA) for the Indian Point nuclear power plant, in order to inform the analysis being conducted by the New York State Department of Environmental Conservation (NYSDEC) under the New York State Environmental Quality Review Act (SEQRA). Synapse found that the retirement of the Indian Point nuclear facility would result in essentially no reliability impacts and minimal air emission impacts.
Direct Testimony of Bob Fagan Regarding Air Emissions and Electric System Reliability Impacts of Closed-Cycle Cooling
Rebuttal Testimony of Bob Fagan Regarding Air Emissions and Electric System Reliability Impacts of Closed-Cycle Cooling
Surrebuttal Testimony of Bob Fagan Regarding Air Emissions and Electric System Reliability Impacts of Closed-Cycle Cooling
Synapse is engaged in ongoing work on behalf of Appalachian Mountain Advocates (AMA) and the Southern Environmental Law Center to analyze natural gas demand and proposed pipeline expansion in Virginia and the surrounding region. Related to this, AMA commissioned Synapse to assess the cost and potential for renewables in Virginia, including both renewable energy sources built in state and renewable energy produced in the surrounding region and purchased by Virginia. Synapse found that wind and solar energy showed the greatest potential for Virginia considering technical potential, economic feasibility, and integration concerns.
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.
In Maine, the Efficiency Maine Trust plans for and administers all energy efficiency programs across the state in an integrated fashion, including those funded from electric and natural gas ratepayers, in accordance with three-year plans that must be approved by the Maine Public Utilities Commission. Synapse assisted the Natural Resources Council of Maine in its review of the Trust’s 2014 plan for its first statewide natural gas energy efficiency programs by providing analysis and testimony regarding maximum achievable cost-effective (MACE) savings and budgets. Synapse also provided high-level input on implementation issues, gas conservation strategy, and planning best practices.
On behalf of the Natural Resources Council of Maine (NRCM) and the Conservation Law Foundation, Synapse provided technical support and expert testimony in the Maine Public Utilities Commission’s review of the Efficiency Maine Trust’s Triennial Plan for Fiscal Years 2017-2019. Synapse’s Tim Woolf submitted direct testimony that assessed the key assumptions used in the plan, reviewed the energy efficiency potentials used in preparing the plan, and assessed the plan’s likelihood of reaching the maximum achievable cost-effective (MACE) potential for gas and electricity customers. The testimony included recommended modifications for reaching MACE.
Synapse prepared expert testimony on behalf of Sierra Club on the Georgia Power Company 2016 Integrated Resource Plan and Demand-Side Management Plan. The testimony built off of participation in a multi-stakeholder working group over several months. The testimony critiqued the planning process used to develop the DSM Plan, critiqued the cost-effectiveness analysis used to develop the DSM Plan, recommended an expanded set of DSM programs, and recommended that Georgia Power Company conduct a comprehensive rate and bill impact analysis to assess the equity issues raised by the DSM programs.
New England’s growing dependence on natural gas has had some in the region worrying about supply constraints. In fact, concerns about natural gas supply and the impacts of proposed new pipelines prompted no fewer than three separate studies on the issue last year. In 2015, three consulting firms released separate reports for different clients analyzing the need for incremental natural gas pipeline in New England through 2030. The three distinctly different approaches to the studies have the potential to create uncertainty for those trying to compare the results. To address this confusion, Synapse produced a white paper which reviews the main differences in the methods and inputs for each of the three studies, along with their results and key findings.
Synapse through its subcontractor John Rosenkranz, provided New Jersey Rate Counsel with technical advice to review New Jersey Natural Gas' annual Basic Gas Supply Service (BGSS) and Conservation Incentive Program (CIP) filings.
Synapse reviewed the modeling methodology used by Portland General Electric (PGE) in the development of its 2016 Draft Integrated Resource Plan. Synapse found that PGE’s methodology lacked rigor and, as such, did not sufficiently justify its portfolio selection for the draft IRP. In comments submitted on behalf of Sierra Club during a stakeholder feedback process, Synapse recommended that PGE address the flaws in the selection process by (1) conducting optimization modeling, (2) performing a probabilistic analysis, (3) replacing its unreliable metrics with standard measures, (4) providing scenario results to stakeholders, and (5) involving stakeholders in future procurement decisions.
Comments to Oregon PUC on PGE 2016 Integrated Resource Plan
On behalf of the New Jersey Division of Rate Counsel, Synapse reviewed and provided comments on the proposed revisions to New Jersey's technical reference manual titled "New Jersey Clean Energy Program Protocols to Measure Resource Savings." Synapse's comments focused on the key data sources; assumptions and savings algorithms for various end uses; and projects such as ground source heat pump, HVAC, hot water, LED lighting, new construction, appliances and electronics.
On behalf of Sierra Club, Synapse reviewed the Tucson Electric Power Company’s (TEP) rate application submitted to the Arizona Corporation Commission. Specifically, Synapse reviewed TEP’s decision to retire the San Juan Generation Station (SJGS) Unit 1 in 2027 and its request to recover costs from ratepayers for a $34 million investment in two pollution control projects at the unit. Synapse found that TEP did not exercise due diligence in supporting its recommendation of a 2027 retirement and its capital expenditures, relying heavily on another owner of the plant, Public Service Company of New Mexico. TEP conducted its own analysis in 2012 and 2013, prior to several major changes that affect the economics of San Juan. Synapse’s analysis found that the unit is unlikely to be economic after 2022. As such, Patrick Luckow submitted expert testimony recommending that the Commission reject the proposed 2027 retirement in favor of a 2022 retirement.
Synapse analyzed least-cost strategies for reducing emissions 40 percent below 1990 levels in Regional Greenhouse Gas Initiative (RGGI) states by 2030. Synapse’s analysis focused on four well-researched, cost-effective emission reduction measures: energy efficiency, wind and solar generation in the electric sector, and conversion from gas-powered to electric light-duty vehicles in the transportation sector. Using a purpose-built version of Synapse's Multi-Sector Emissions Model (MSEM) and the National Renewable Energy Laboratory’s Regional Energy Deployment System (ReEDS) to model emissions in the RGGI states, Synapse analyzed the impacts of adding the following measures to the RGGI states’ existing goals:
- Converting one-third of all light-duty vehicles from gas to electric
- Achieving Massachusetts’ level of energy efficiency savings in all RGGI states
- Investing in onshore wind generation up to the economically achievable potential
- Limited investments in utility-scale solar installations
Version 2.0 of the resulting report considers the gas and oil savings (co-benefits) from electric energy efficiency measures and the electric savings from gas energy efficiency measures. It also includes two new carbon dioxide emission reduction measures that were not considered in our original January 2016 report:
- Gas energy efficiency measures in the residential, commercial, and industrial sectors
- The replacement of aging residential oil heating systems with air-source heat pumps (efficient electric heating units)
In addition, this study:
- revises the methodology for choosing which emission reduction measures to include in the modeling by incorporating the cost of powering electric vehicles with renewables;
- reallocates the installation of onshore wind generators across Northeast states to be more consistent with expected wind speed potential; and
- uses updated levelized costs of energy for onshore wind and utility-scale solar, reflecting the best information available at the time of publishing.
- With these measures in effect, lower emission reductions are required of the electric sector to reach the same 40-percent all-sector emissions reduction target for the nine Regional Greenhouse Gas Initiative states.
Subsequent to this study, Synapse presented a webinar in which Synapse staff used RGGI as a case study to demonstrate the use of Synapse's Multi-Sector Emissions Model (M-SEM). View presentation here.
The RGGI Opportunity 1.0
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 reviewed the engineering aspects of Rockland Electric Company’s recent distribution system investments included in the Company’s recent rate case.
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.
Jurisdictions across the country are grappling with the challenges and opportunities associated with rapidly increasing adoption of distributed solar resources. While distributed solar can provide many benefits – such as increased customer choice, decreased emissions, and decreased utility system costs – in some circumstances it may result in increased bills for non-solar customers. Utility regulators and state policy-makers face the difficult task of striking a balance between ensuring that cost-effective clean energy resources continue to be developed, and avoiding unreasonable rate and bill impacts for non-solar customers.
This report, prepared by Synapse for Consumers Union, provides a framework for helping decision-makers analyze distributed solar policy options comprehensively and concretely. This framework is grounded in addressing the three key questions that regulators should ask regarding any potential distributed solar policy:
- How will the policy affect the development of distributed solar?
- How cost-effective are distributed solar resources?
- 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.
Show Me the Numbers Slide Deck
The New York Public Service Commission has undertaken an ambitious initiative to improve system efficiency, empower customer choice, and encourage greater penetration of clean generation and efficiency technologies. Called the Reforming the Energy Vision initiative, or REV, this case has proceeded on two tracks. The focus of Track Two is to examine what regulatory changes in current regulatory, tariff, and market designs and incentive structures are needed to better align utility interests with achieving the PSC’s objectives. Synapse provided the Natural Resources Defense Council (NRDC) with analytical and policy expertise to help NRDC ensure that REV Track Two: (1) results in a regulatory and ratemaking model for New York that moves away from electricity as a commodity, (2) promotes the penetration of clean and renewable resources, (3) ultimately decarbonizes the electric sector, and (4) becomes a model for other jurisdictions. Synapse assisted NRDC in this matter by conducting and quantitative research and analysis to inform NRDC comments and proposals, developing and executing work plans for strategic engagement in REV Track Two, working with NRDC to draft submissions to the PSC, and otherwise participate in REV-related stakeholder processes, where required.
Synapse also assisted NRDC with Track One issues.
Comments on New York State Department of Public Service Reforming the Energy Vision Benefit-Cost Analysis White Paper
Reply Comments on New York State Department of Public Service Reforming the Energy Vision Benefit-Cost Analysis White Paper
Comments on New York State Department of Public Service Reforming the Energy Vision Track 2 White Paper
Reply Comments on New York State Department of Public Service Reforming the Energy Vision Track 2 White Paper
Comments on New York State Department of Public Service Distributed System Implementation Plan Guidance
Reply Comments on New York State Department of Public Service Distributed System Implementation Plan Guidance
Comments on New York Public Service Commission Initial Distributed System Implementation Plans
Reply Comments on New York Public Service Commission Initial Distributed System Implementation Plans
Comments on New York Public Service Commission Supplemental Distributed System Implementation Plans
Reply Comments on New York Public Service Commission Supplemental Distributed System Implementation Plans
Comments on VDER Phase 1 Implementation Plans
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."
The National Standard Practice Manual and the Value of Energy Efficiency in New York
Value of Energy Efficiency in New York: Assessment of the Range of Benefits of Energy Efficiency Programs
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