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Synapse is providing expert technical consulting services to the Delaware Department of Natural Resources and Environmental Control (DNREC) related to Exelon Corporation’s proposed acquisition of Pepco Holdings Incorporated. Specifically, Synapse reviewed the value of the benefits and commitments of the merger and concerns regarding concentration of ownership, market power, and market manipulation in the wholesale electricity market. Synapse is submitting testimony in the legal proceeding on behalf of DNREC. Synapse performed similar analysis related to the merger on behalf of clients in Maryland, New Jersey, and the District of Columbia.
Direct Testimony of Paul Peterson Regarding Concentration of Ownership, Market Power, and Potential Market Manipulation Related to the Proposed Exelon-Pepco Merger in Delaware
Synapse and a team of subcontractors developed projections of electricity and natural gas costs that would be avoided due to reductions in electricity and natural gas use resulting from improvements in energy efficiency. The 2018 report provides projections of avoided costs of electricity and natural gas by year from 2018 through 2035 with extrapolated values for another 15 years. In addition to projecting the costs of energy and capacity avoided directly by program participants, the report provides estimates of the Demand Reduction Induced Price Effect (DRIPE) of efficiency programs on wholesale market prices for electric energy, electric capacity, and natural gas. The report also provides a projection of avoided costs of fuel oil and other fuels, non-embedded environmental costs associated with emissions of CO2, avoided costs of transmission and distribution, and the value of reliability. The 2018 AESC study was sponsored by a group representing all of the major electric and gas utilities in New England as well as efficiency program administrators, energy offices, regulators, and advocates. Synapse conducted prior AESC studies in 2007, 2009, 2011, and 2013.
Visit our AESC 2018 Materials page to download the AESC 2018 report appendices, user interfaces, and a slide deck on the study findings.
Synapse has also conducted supplemental analysis on the avoided costs of compliance of the Massachusetts Global Warming Solutions Act. Visit here for more details.
Avoided Energy Supply Components in New England: 2018 Report (June Re-Release)
Avoided Energy Supply Components in New England: 2018 Report (March 30 Release)
Avoided Energy Supply Costs in New England: 2013 Report
Avoided Energy Supply Costs in New England: 2011 Report
Avoided Energy Supply Costs in New England: 2009 Report
Avoided Energy Supply Costs: 2007 Final Report
Affidavit Regarding the Avoided Energy Supply Cost 2011 Report
Highlights of AESC 2011 Report: Presentation to the Vermont Public Service Board
Highlights of AESC 2011 Report: Presentation to Efficiency Maine Trust
Highlights of 2009 AESC Report: Presentation to the Vermont Public Service Board
Electricity Cost Highlights of Avoided Energy Supply Costs in New England 2007 Final Report
In collaboration with the Lawrence Berkeley National Laboratory, Synapse is assisting the Advanced Manufacturing Office of the U.S. Department of Energy in developing a set of resources (i.e., a toolkit) to demonstrate the value and communicate the approach of the Better Buildings Initiative - Superior Energy Performance (SEP) Accelerator to utilities, regulators, and industrial customers. Integrating input from key energy efficiency program administrators (PAs), Synapse is developing a toolkit providing the necessary information, resources, frameworks for analysis, and case studies that will facilitate the development and deployment of ratepayer-funded SEP program offerings. Among other resources, the toolkit includes a Cost Effectiveness Screening Tool to assist PAs with determining if developing offerings for SEP is likely to achieve positive net benefits, and a SEP Filing Guide to provide PAs with guidance on the information to include in their program plans.
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
In 2018 the U.S. Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA) issued a proposal to roll back existing Corporate Average Fuel Economy (CAFE) and tailpipe greenhouse gas (GHG) emission standards for light-duty vehicles to model year 2020 levels. Under the existing CAFE and GHG standards, requirements grow increasingly stringent through model year 2025. On behalf of the California Department of Justice, Synapse evaluated the macroeconomic impacts of the proposed rollback. We found that (1) the agencies' own analysis indicated that the proposed rollback would result in job losses; (2) the proposed rollback would result in reduced vehicle sales; (3) when accounting for broader economic impacts, the proposed rollback would result in greater job losses than those predicted under the agencies' analysis; and (4) the proposed rollback would negatively impact U.S. gross domestic product.
On behalf of the Illinois Office of the Attorney General, Synapse reviewed Commonwealth Edison Company’s (ComEd) proposal for a voltage optimization validation project within the context of ComEd’s formula rate proceeding. Principal Associates Max Chang and Bob Fagan submitted testimony before the Illinois Commerce Commission (Case 16-0259) addressing ComEd’s planned Voltage Optimization Validation Program and its opportunities for data analytics. Synapse’s analysis found that ComEd’s validation study did not adequately demonstrate that the program would address the company’s challenges. Mr. Chang and Mr. Fagan recommended that the Commission direct ComEd to adopt a more comprehensive and robust validation study for voltage optimization. Mr. Chang and Mr. Fagan also recommended that the Commission require ComEd to provide information regarding the development of a long-term plan to fully utilize data gathered from the installation of smart meters and modern distribution infrastructure.
On behalf of Save the Sound, Synapse is comparing recent studies on the need for new and expanded natural gas pipeline infrastructure proposed by Kinder Morgan subsidiary Tennessee Gas Pipeline in Connecticut and surrounding states. Within the context of Connecticut energy demand and climate laws, the team is reviewing and synthesizing the findings of three separate New England natural gas demand reports released in 2015, examining issues related to compliance with Connecticut’s Global Warming Solutions Act, and placing these findings in the context of expected near- and medium-term capacity and demand of natural gas in Connecticut.
Sierra Club retained Synapse to review Dayton Power and Light’s (DP&L) application for approval of an electric security plan (Cases No. 16-0395-EL-SSO, 16-396-EL-ATA, and 16-397-EL-AAM). Synapse’s review focused on DP&L’s proposed Distribution Modernization Rider (DRM) and the value and outlook of the Company’s coal fleet. The proposed DRM would charge ratepayers $145 million per year over seven years. These charges would subsidize risky capital investments in the Company’s coal assets—several of which have been determined by other owners to have value and be unreliable. On behalf of Sierra Club, Tyler Comings submitted testimony to the Public Utilities Commission of Ohio demonstrating the coal fleet’s low value and poor reliability and recommending that the Commission deny the DMR.
Synapse was retained to provide expert witness and consulting services to the Hawaii Division of Consumer Advocacy in a proceeding to develop and review integrated resource plans (IRPs) for three electric companies. Topics include scenario planning, resource modeling, community and stakeholder input processes, and analysis of locally produced biofuels, wind and solar energy opportunities (both distributed and large scale), battery storage, and other renewable energy options. The three major electric companies supplying 95 percent of Hawaii’s electricity are simultaneously facing the need to retrofit or replace existing generation impacted by new environmental regulations and the onset of a very stringent renewable portfolio standard (40 percent by 2030). Imported fossil fuel costs are the primary driver behind high electricity rates and subject Hawaiian residents to rapidly fluctuating prices. Currently all of the Hawaiian Islands operate their electricity systems independently; a major planning issue going forward is interconnecting several of the islands using undersea cables in order to better integrate and manage high levels of variable renewable energy. On behalf of the client, Synapse is reviewing these key issues and addressing how best to meet future constraints and policy goals while minimizing costs to consumers.
Direct Testimony of Rick Hornby Regarding HECO & HELCO’s Application for a Biofuel Supply Contract with AKP
Direct Testimony of Patrick Luckow Regarding HECO & HELCO’s Application for a Biofuel Supply Contract with AKP
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.
Since 2007, Synapse has assisted the Cape Light Compact with various aspects of their participation in the New England Forward Capacity Market (FCM). Project ongoing.
The Massachusetts restructuring law enables municipal aggregators to implement energy efficiency programs with funds raised from all customers through a system benefits charge. More than 20 years ago, Synapse designed the energy efficiency programs that are being provided by the Cape Light Compact, the municipal aggregator on Cape Cod. Since then, Synapse has assisted the Cape Light Compact (the Compact) with energy efficiency plan, annual report, and energy efficiency charge reconciliation filing preparation, including energy efficiency data reporting and analysis and policy support. Energy efficiency data reporting and analysis includes processing of data from the Compact’s database into tables for plans and reports and analysis of the plans and reports, preparation of the exhibits for the energy efficiency charge reconciliation filing, and drafting of memos on key aspects of filings as needed to inform stakeholder review. Policy support includes implementing key outcomes of Massachusetts Department of Public Utility (MA DPU) Orders, developing positions in open dockets, representing the Compact in stakeholder working groups, and providing expert testimony before the MA DPU.
The Cape Light Compact Energy Efficiency Plan Phase II: 2003-2007
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.
In response to the Virginia State Corporation Commission’s questions on evaluation, measurement, and verification (EM&V) methods, Synapse prepared a memo where we reviewed, summarized, and provided recommendations with respect to current EM&V practices in Virginia, national best practices, and emerging practices enabled by the development and adoption of new information and communications technologies. The memo also discussed inputs and recommendations for methodologies to calculate the levelized cost of saved energy. The Virginia Energy Efficiency Council included the memo with its May 25, 2016 comments to the State Corporation Commission in Case PUE-2016-00022.
Synapse is providing expert assistance and testimony on behalf of the U.S. Department of Justice in connection with its investigation of potential violations of the Clean Air Act by Ameren Missouri.
Synapse is assisting the Hawaii Division of Consumer Advocacy in an investigation to reexamine the existing decoupling mechanisms for the Hawaiian Electric Companies (Docket 2013-0141). The Hawaii Public Utilities Commission opened this investigation to determine whether the existing decoupling mechanisms, including both the Revenue Balancing Account (RBA) and the Revenue Adjustment Mechanism (RAM), are effectively serving their intended purposes, are fair to the HECO Companies and ratepayers, and are in the public interest. Schedule A of this docket addressed interest rates, tax deferrals, risk sharing mechanisms, baseline projects in RAM, and performance metrics. Schedule B of this docket will address issues concerning the RAM, particularly related to the incentives that the RAM provides or fails to provide, the fair allocation of risk, and ways to increase the efficiency of ratemaking. Synapse is taking a lead role in reviewing and commenting on the development of HECO’s performance metrics associated with Schedule A, and is leading the development of the Consumer Advocate’s statements of position regarding performance incentives in Schedule B, including analysis of how such incentives might interact with the decoupling mechanism.
Synapse is providing technical and expert witness services to the California Public Advocates Office in connection with the Long Term Procurement Plan proceeding affecting the three largest investor-owned utilities in California: Southern California Edison, Pacific Gas and Electric, and San Diego Gas and Electric. As part of this project, Synapse conducted modeling of the California ISO (CAISO) area using PLEXOS to assess loads and emissions throughout California based on various California Public Utilities Commission scenarios. Synapse analyzed model inputs, assumptions, forecast projections, and outputs, and examined alternatives including renewable energy integration and retirement scenarios. Synapse’s modeling enabled determination of areas within California that would be capacity constrained.
Reply Testimony of Bob Fagan and Patrick Luckow in Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans
Reply Testimony of Bob Fagan and Thomas Vitolo in Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans
Since 2005, Synapse has provided monitoring and representation services for CSG and small companies associated with CSG who have recently become NEPOOL members in the new NEPOOL Alternative Resources sector. CSG was sold to CLEAResult in 2015, and Synapse continues this work with the successor organization. In 2006, VEIC became a NEPOOL member and a Synapse client for whom Synapse provides information and representation services. The Alternative Resources sector is comprised of providers of energy efficiency, renewable, distributed generation, and demand response resources.
Executive Summary Only: Incorporating Energy Efficiency into the ISO New England Forward Capacity Market
NEPOOL’s governance structure allows non-profits and other customer representatives to become voting members. Since 2001, Synapse has provided representation and voting services to non-profit and consumer interest clients. Our clients have included PowerOptions, The Energy Consortium, Harvard, the Union of Concerned Scientists, and MASSPIRG.
Since 2001, Synapse has engaged in NEPOOL and ISO New England committee and working group meetings on behalf of consumer advocate clients in NEPOOL’s End Use sector. Our clients have included consumer advocate offices in Maine, New Hampshire, Connecticut, and Massachusetts. Synapse has provided representation services (voting) in addition to monitoring and information services to all of these NEPOOL clients.
Demand Response Potential in ISO New England’s Day-Ahead Energy Market
Wholesale Natural Gas Prices in New England
Comments on the Procurement of Default Service Power Supply for Residential, Small Commercial, and Industrial Customers in the Commonwealth of Massachusetts
Comments on the Draft 2015 Solar PV Forecast
Comments on 2018 Draft Energy Efficiency Forecast
Synapse is assisting the New Jersey Division of Rate Counsel with analyzing program characteristics of a Societal Benefits Charge (SBC) Credit Program, being implemented in rulemaking Docket No. EO12100940. To this end, Synapse will conduct supporting research, such as reviewing other states’ programs; attend working group meetings; and assist with preparation of comments. Analysis will include consideration of the following: energy reduction thresholds, the costs and feasibility of various options for credit issuance other than a reimbursement check, a SBC Budget to minimize the financial impact of the credit on other Clean Energy Programs, charging applicants an administrative fee to cover program administration costs, how the fee requirement would be administered, and other issues.
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
Consulting on issues concerning utility rate proposals that seek to establish incentives to create non-wires alternatives to transmission and distribution investments.
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.
The New Jersey Division of Rate Counsel retained Synapse to review PSEG’s base rate adjustment proposal based on the roll-in schedule of the PSEG’s Energy Strong investment program.
Synapse is providing the Maryland Office of People’s Counsel (OPC) with technical assistance and testimony in Case No. 9406 regarding Baltimore Gas and Electric Company’s (BGE) electric rate increase request to recover costs for smart grid implementation and other costs. The increase of approximately $135.2 million is intended to pay for implementation of advanced metering infrastructure and underground conduit costs in Baltimore. Synapse staff and subcontractor Nancy Brockway submitted testimony covering the benefit cost analysis of the advanced meter infrastructure investments and cyber-security/ privacy concerns associated with the implementation of advanced meter infrastructure investment across the BGE service territory.
Synapse has been retained to evaluate National Grid’s Massachusetts rate design proposals, filed as part of its 2016 rate case. In its application, the Company proposed to impose tiered customer charges on residential and small commercial customers intended to act as a proxy for a demand charge. Synapse submitted testimony that demonstrated why the Company’s proposal not only failed to improve customer equity, but would also be unnecessarily complex, difficult for customers to respond to, and would undermine price signals for energy efficiency and distributed energy resources. Specifically, Synapse conducted statistical analysis to show that the Company’s proposed proxy for a demand charge was no better of an indicator of customer demand than an energy charge, and also failed to account for customer demand diversity and the coincidence with system peak demands.
Rebuttal Testimony of Tim Woolf and Melissa Whited Regarding National Grid Rate Design Proposal
Synapse is reviewing performance incentive mechanisms for HELCO and HECO on behalf of the Division of Consumer Advocacy.
Indiana Michigan Company (I&M) submitted an application to the Indiana Utility Regulatory Commission seeking a certificate of public convenience and necessity to install Selective Catalytic Reduction at Rockport Power Plant Unit 2 near Rockport, Indiana. Synapse assessed the analysis conducted by American Electric Power Generating Services on behalf of I&M in support of the application. Specifically, Synapse examined if the installation of the controls would be in the interest of I&M’s ratepayers and if the proposal was consistent with regulatory requirements. On behalf of Citizens Action Coalition of Indiana, Sierra Club, and Valley Watch, Dr. Jeremy Fisher submitted testimony to the Commission recommending that the Commission deny the CPCN on the basis that the Company’s analysis is outdated and Rockport 2 is not a reasonable long-term resource.
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