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Client:
Minnesota Department of Commerce
Year:
2021

The Minnesota Department of Commerce, Division of Energy Resources retained Synapse to support its exploration of privacy and security issues related to Minnesota utilities’ hosting capacity analyses (HCA) and distribution grid data. As with other jurisdictions modernizing the grid, Minnesota seeks to balance the data access needed to support distributed energy resource (DER) uptake with maintaining a secure grid that protects the privacy of customers.

 Xcel Energy (Xcel), Minnesota’s largest electricity provider, has made its HCA available via an online map, but blurs the display of the data in a way that does not reveal discrete circuits, and provides less system information. Xcel claims that an unblurred map would make the distribution grid unnecessarily vulnerable to attack and would jeopardize customer security and confidentiality.

Synapse wrote a report stating that Xcel should unblur its HCA map and place it behind a verified web login portal that is open to the public. In reaching this conclusion, Synapse noted that:

  • Location information on distribution facilities is likely already in the public domain
  • Various tools exist to help map distribution lines
  • Providing distribution line information provides significant value to DER developers
  • Focusing on strengthening the grid’s physical and cybersecurity defenses, and increasing grid resiliency, is more effective at deterring attackers than concealing information.

For sensitive grid data, such as peak substation and feeder loads, which is currently not provided on the HCA map, Synapse recommended applying a risk/cost-benefit framework to balance grid security with the public benefits of HCA map data. The framework could help determine whether specific, sensitive grid data should be published on its HCA map, and how secure access to this data should be provided. Synapse suggested that Xcel consider a tiered-access approach that helps streamline access to non-public grid data and does not make requirements unnecessarily burdensome.

Related Publication(s)
Hosting Capacity Analysis and Distribution Grid Data Security
Client:
Energy Outreach Colorado
Year:
2021

On behalf of Energy Outreach Colorado, Synapse submitted testimony regarding the impact of Public Service Company of Colorado's proposal to eliminate inclining block rates (IBR). Synapse's analysis revealed that inclining block rates are more cost-reflective than flat rates, and that eliminating IBR would have disproportionately negative impacts on low-income customers, as these customers tend to have lower usage than average. Further, Synapse's testimony supported empowering customers to better manage their electricity bills by providing customers with cost-reflective rate options. 

Related Publication(s)
Cross-Answer Testimony of Melissa Whited
Answering Testimony of Melissa Whited
Client:
Sandia National Laboratories
Year:
2021

In 2019, Sandia National Laboratories contracted Synapse Energy Economics to improve understanding and provide guidance on the challenges and opportunities facing communities and electric utilities seeking to coordinate energy-related resilience efforts. The research was funded by the U.S. Department of Energy and conducted as part of the Grid Modernization Laboratory Consortium’s Designing Resilient Communities: A Consequence-Based Approach for Grid Investment (DRC) project. Synapse was one of several government, industry, and university partners on the project team and provided expertise on electric utility regulation.

Synapse produced a series of five reports exploring several important topics related to its area of focus, including:

  • Current landscape: structured interviews with six community and utility pairs to better characterize the existing state of resilience planning within and across jurisdictions and identify opportunities for improvement;
  • Benefit-cost analysis for grid investments in resilience: the first application of the framework developed in the 2020 National Standard Practice Manual for Benefit-Cost Analysis of Distributed Energy Resources to grid resilience investments;
  • Resilience performance metrics: guidance for jurisdictions to take the important step of defining and establishing performance metrics for resilience;
  • Resilient public purpose microgrids: definition of the term and characterization of five project types that may be more likely to receive ratepayer funding; and
  • Regulatory mechanisms to support resilience: mechanisms that electric utility regulators can use to align grid resilience investments with resilience interests and priorities.
Related Publication(s)
The Resilience Planning Landscape for Communities and Electric Utilities
Application of a Standard Approach to Benefit-Cost Analysis for Electric Grid Resilience Investments
Performance Metrics to Evaluate Utility Resilience Investments
Excel Tool: Performance Metrics to Evaluate Utility Resilience Investments
Regulatory Mechanisms to Enable Investments in Electric Utility Resilience
The Quest for Public Purpose Microgrids for Resilience: Considerations for Regulatory Approval
Client:
Colorado Energy Office
Year:
2021

Synapse authored a white paper for the Colorado Energy Office (CEO) in support of CEO's participation in rule-making and dockets around planning for the future of gas utilities in the state. Colorado has taken important first steps to require a transformation in the gas sector in order to reduce emissions, and the white paper proposes using an observe-orient-decide-act framework to foster iteration and learning, while also reflecting the fact that decisions need to be made without complete information about the final state of building decarbonization. Synapse's team adapted a change management paradigm to identify the key considerations for gas planning and map them onto the expected rule-making, plans, and other processes in Colorado.

Related Publication(s)
A Framework for Long-Term Gas Utility Planning in Colorado
Client:
Natural Resources Defense Council
Year:
2021

The Natural Resources Defense Council (NRDC) retained Synapse to analyze the macroeconomic impacts of light-duty vehicle greenhouse gas (GHG) standards and zero emission vehicle (ZEV) policies in the state of Illinois. We assessed the likely employment and GDP impacts in Illinois for three policy scenarios: (1) adoption of low emission vehicle (LEV) tailpipe standards for criteria pollutants and GHGs, and ZEV regulations; (2) the LEV standards with increased ZEV penetration that achieves Governor Pritzker’s goal of 750,000 ZEVs by 2030; and (3) the LEV standards with further ZEV penetration that achieves 100 percent ZEV sales by 2035. Our analysis found that each of the three policy scenarios is likely to result in small but positive long-term macroeconomic impacts in Illinois and that employment and GDP benefits grow as each policy scenario becomes more aggressive in its assumed number of LEVs and ZEVs in Illinois.

Related Publication(s)
Macroeconomic Analysis of Clean Vehicle Policy Scenarios for Illinois
Client:
Maryland Office of People’s Counsel
Year:
2021

Synapse provided the Maryland Office of People’s Counsel (OPC) with technical assistance in evaluating the likely impacts on Maryland ratepayers from pursuing the fixed resource requirement (FRR) alternative to continued participation in PJM's capacity market. The FRR alternative is the main avenue for states to avoid the negative impacts of the Federal Energy Regulatory Commission's (FERC's) controversial minimum offer price rule (MOPR) order on the development of renewable resources and the cost to achieve state clean energy goals.

As part of this work, Synapse developed a three-step framework for assessing the potential impacts of the FRR alternative. The framework was proposed to evaluate the economic and financial trade-offs between the FRR alternative and continued participation in PJM's capacity market and the state regulatory and legislative actions that may be necessary to support pursuit of the FRR alternative. This included evaluating the potential benefits and costs to Maryland ratepayers from pursuit of the FRR alternative and an assessment of the legislative and regulatory actions necessary to pursue the FRR option if the benefits are determined to exceed the costs. As part of this effort, Synapse conducted in-depth analysis on the benefits and costs associated with FRR, including changes in cost to meet clean energy goals, changes in capacity procurement quantities, and market power impacts.

Client:
Union of Concerned Scientists
Year:
2021

Energy equity is an emerging topic, and explicitly addressing energy equity in energy planning processes and practices is relatively new for utilities and their regulators. Within the energy system, equity involves a just distribution of costs and benefits of investments in the electric grid and other energy infrastructure and the accessibility of affordable and clean energy across customers in a utility service territory. Energy equity also involves the ability of customers to participate in, provide input on, and influence the decision-making processes that impact them. The practices employed by leading utilities and states highlight the following deficiencies regarding energy equity in Evergy’s Kansas IRP filing:

    -The IRP filing does not mention equity as a goal;
    -It does not identify strategies to improve equity;
    -It does not include a resource planning scenario with higher investments in strategies that improve equity;
    -It does not select scenarios with consideration of equity-related metrics among other metrics; and
    -It does not include differential treatment for environmental justice communities and overburdened customers.

The purpose of this report is to guide Evergy Kansas and the Kansas Corporation Commission in improving equity in their electricity-related policies, practices, programs, and decision-making, with a focus on opportunities related to the IRP. There are a wide range of policies and practices in use to improve equity in jurisdictions across the country that can be applied in Kansas. This report seeks to characterize the current landscape of policies and practices, identify jurisdictions leading the way, provide resources with more information on how to improve equity, and leverage this information to recommend some initial steps for Evergy in Kansas.

Related Publication(s)
Opportunities for Evergy Kansas to Address Energy Equity Within its Integrated Resource Plan and Other Planning Processes
Client:
Carolina Utility Customers Association
Year:
2021

In response to legislation, the North Carolina Utilities Commission initiated proceedings regarding the implementation of performance-based regulation (PBR). On behalf of the Carolina Utility Customers Association, Synapse developed initial and reply reports to inform the rulemaking process. Our reports focused on customer protections necessary to ensure that PBR in North Carolina serves the public interest. Our recommendations highlight the need for greater transparency in utility planning and capital investment forecasts, establishing benchmarks and robust reporting for utility costs, and returning any under-spend to ratepayers to ensure that the utilities do not profit by overstating their cost forecasts.

Related Publication(s)
Implementing PBR with Customer Protections in North Carolina
Additional Recommendations for Implementing PBR with Customer Protections in North Carolina
Client:
Puerto Rico Energy Bureau, Regulatory Assistance Project
Year:
2021, 2020, 2019, 2018, 2017, 2016, 2015

Synapse has been engaged with the Puerto Rico Energy Commission, now named the Puerto Rico Energy Bureau, since 2015. Our role includes providing technical support and expert review of materials submitted by the Puerto Rico Electric Power Authority (PREPA, the island's sole electric utility). In early 2015, Synapse was engaged by the Regulatory Assistance Program (RAP) to help develop Puerto Rico's first Integrated Resource Planning (IRP) rules. The rule was successfully promulgated in May 2015. Subsequently, Synapse collaborated with RAP to assess PREPA's first IRP, and lead a commission investigation into the development and finalization of the IRP. Over the course of 2015 and into early 2016, Synapse led an increasingly intensive review of the IRP process and findings, as well as the Commission’s first public hearing. The IRP Final Order, largely a result of Synapse's work, was published September 2016.

We have also assisted the Bureau in crafting rules for microgrids and developing performance metrics and incentives. In the wake of Hurricanes Irma and Maria, we have also supported the Bureau as it guides the utility through its second IRP in the context of expected privatization or concessionaire structures for both generation and electric grid operations. Our engagement in Puerto Rico has been conducted in close partnership with the Regulatory Assistance Project (RAP). Together, we act as a resource for support and an expansion of the technical and regulatory expertise available to the recently formed regulator.

In 2020, Synapse supported the Puerto Rico Energy Bureau in:

  1. Completion of the 2019 Integrated Resource Plan process and associated follow-up;
  2. development and execution of the Optimization proceeding to develop decision-making approaches for resilience investments;
  3. development of revised demand response and energy efficiency regulations, as well as beginning development of the required cost-effectiveness screening framework and avoided costs; and
  4. evaluation and development of performance metrics and structures for PREPA and LUMA.

 

Client:
Nova Scotia Utility and Review Board
Year:
2021

Nova Scotia Power Inc (NSPI) filed a proposal in June 2021 to implement a pilot solar garden rate rider, which would establish the charges and solar generation credits that subscribing customers receive from a 2 MW solar garden being constructed in Amherst, Nova Scotia. On behalf of the Counsel for the Nova Scotia Utility and Review Board, Synapse’s Melissa Whited submitted written evidence regarding aspects of the proposal that are inconsistent with recent provincial policy developments, particularly with respect to carbon emissions policy, and about the benefits of the program to subscribers. The evidence also identified areas where additional information and transparency are needed and recommended that the Board make requirements with respect to tracking and reporting on the performance of the program, the output of the solar garden, and subscription revenues. In its decision on this matter, the Board ordered NSPI to provide, at the end of the pilot, analysis to consider rider amendments to reflect the learnings from the pilot and account for changes in environmental compliance costs.

Related Publication(s)
Evidence Regarding NSP's Solar Garden Rate Rider Proposal - Melissa Whited
Evidence Regarding NSP's Solar Garden Rate Rider Proposal - Appendix A
Client:
New Jersey Division of Rate Counsel
Year:
2021

New Jersey Rate Counsel retained Synapse to review PSEG Nuclear and Exelon Generation's application for the Round Two Zero Emissions Credits for the Salem and Hope Creek nuclear plants. The two applicants sought the New Jersey Board of Public Utilities to provide approximately $300 million per year through 2025 to preserve the two nuclear plants. Synapse reviewed detailed financial information provided by the two applicants. Synapse provided testimony to support New Jersey Rate Counsel's position that the nuclear subsidies were not needed at the amount sought by the two applicants.

Client:
Sierra Club
Year:
2021

Synapse provided expert testimony and analysis to support the Sierra Club in reviewing Indiana Michigan Power Company (I&M)’s Power Supply Cost Recovery (PSCR) Plan for the calendar year 2021 in Michigan Public Service Commission Docket U-2804. Synapse testimony focused on evaluating the prudence of I&M’s PSCR plan for 2021. Specifically, we evaluated I&M’s justifications for charging Michigan customers for the purchase of energy from its affiliate, Ohio Valley Electric Corporation (“OVEC”) under the Inter-Company Power Agreement (“ICPA”), at above-market prices and review I&M’s oversight of OVEC’s operational and planning decisions. We also evaluated the Company’s operation of the Rockport units and reviewed the fuel and power purchase costs it plans to pass on to customers during the PSCR plan and five-year forecast period.

We found that I&M has been purchasing power from OVEC, an affiliate company, under the ICPA at above market value and passing those costs on to ratepayers since 2017. In 2020 alone, I&M customers incurred $2.5 million in losses relative to the energy market on a variable cost basis, and in total, the ICPA cost I&M customers $26.5 million more than the cost of equivalent energy and capacity in the market. We also found that I&M incurred $25.1 million in net losses relative to the market energy prices in 2020 at the Rockport units on variable cost basis, which could have been mitigated with more prudent unit commitment practices. Finally, we found that I&M's latest fuel cost plan and five-year forecast show that the company will continue to incur net losses in energy market revenue and capacity value by purchasing energy from OVEC under the ICPA and that I&M will continue to uneconomically operate Rockport, and the Company will pass millions in excess costs on to its ratepayers as a result of these actions.

We recommended that the Commission amend the PSCR plan and remove costs incurred under the OVECICPA above the cost of market purchases for energy and capacity. The Company should cap the recovery of costs incurred under the ICPA at the equivalent market value in the future. We also recommend that the commission not allow I&M to develop a PSCR plan that assumes uneconomic commitment of the Rockport units. Finally, we recommend that the Commission indicate that it will disallow recovery of the fuel portion of all net revenue losses incurred as a result of imprudent unit commitment decisions in future reconciliation dockets.

Related Publication(s)
Testimony of Devi Glick Regarding I&M's PSCR
Client:
New Jersey Division of Rate Counsel
Year:
2021

On behalf of the New Jersey Division of Rate Counsel, Synapse provided technical assistance concerning the energy efficiency programs within Public Service Electric and Gas Company (PSE&G)’s 2020 Green Programs Cost Recovery Filing. In this filing to the Board of Public Utilities, PSE&G requested recovery of its historical program spending from 2019 to 2020 and projected spending through 2021.

Synapse evaluated the reasonableness of the historical program spending and savings with a focus on the 2017 Energy Efficiency program that includes sub-programs targeting multifamily buildings, hospitals, small commercial customers, and residential end uses. Synapse investigated spending and savings per participant, costs of saved energy, benefit-cost analysis, and measured specific incentive payments and savings assumptions. Synapse’s assessment revealed that some of the sub-programs were not cost-effective or were substantially more expensive than originally projected. Synapse made several recommendations to improve the cost-effectiveness of these sub-programs.

Client:
Sierra Club
Year:
2021

Synapse supported the Sierra Club in its engagement with Southwestern Public Service (SPS’s) Tolk Station Analysis process. This analysis was required as part of the company's larger Integrated Resource Planning (IRP) process based on an agreement reached between Sierra Club and SPS in a prior rate case. Synapse attended and participated in the Tolk Technical Analysis and IRP workshops and stakeholder sessions on behalf of Sierra Club to review the assumptions and methodology that SPS was using and provide feedback on the reasonableness of the company’s modeling.

Synapse reviewed the final Tolk Analysis report and modeling files provided by SPS and conducted updated modeling runs to correct various errors and concerning assumptions that we identified in SPS’s modeling. Among the omissions that Synapse identified was SPS’s failure to include a carbon price sensitivity in the Tolk Analysis. Synapse included the results of our review of SPS’s report, as well as the results of our updated modeling in a technical report filed with the Commission.

Related Publication(s)
Sierra Club Comments on SPS IRP and Tolk Station Analysis
Client:
Sierra Club
Year:
2021

Synapse provided expert testimony and analysis to support the Sierra Club in reviewing the Southwestern Electric Power Company’s (SWEPCO) fuel cost reconciliation application before the Texas Public Utility Commission for the time period March 2017 through December 2019. Synapse testimony focused on evaluating the Company’s unit commitment practices at its three coal-fired power plants (Flint Creek, Welsh, and Turk) and two lignite-fired power plants (Pirkey and Dolet Hills). We also evaluated the Company’s management of its lignite mining contract at Dolet Hills Mine.

We found that SWEPCO’s lignite units had some of the highest fuel costs among all solid fuel units in the US during this time. We also found that SWEPCO regularly self-committed its coal and lignite plants into the Southwest Power Pool (SPP) market, and as a result incurred substantial net losses. These losses were avoidable through better commitment practices. Finally, we found that SWEPCO imprudently incurred over $170 million at the Oxbow Mine for assets and infrastructure that were not fully used or useful, and now seeks to pass those costs on to its ratepayers.

We recommend that the Commission disallow net operational losses incurred during specific events we identified, as a result of the Company’s uneconomic commitment practices. These losses were avoidable if the units were instead committed into the market with an economic commitment status. We also recommended that the Commission disallow $2.8 million in costs related to the failed expansion of the Oxbow Mine that were incurred and billed to SWEPCO customers during this time period. Finally, we recommend that SWEPCO be required to provide detailed reporting on its daily unit commitment practices.

Related Publication(s)
Direct Testimony of Devi Glick in the Application of SWEPCO's Application to Reconcile Fuel Costs
Client:
Sierra Club
Year:
2021

Synapse provided expert testimony and analysis to support the Sierra Club in reviewing the Southwestern Electric Power Company’s (SWEPCO) rate case application before the Texas Public Utility Commission for the test year April 2019 – March 2020. Synapse testimony focused on evaluating the forward-looking economics of the Flint Creek and Welsh coal plants. Synapse also evaluated the prudence of the SWEPCO's decision to retrofit Flint Creek to comply with coal combustion residuals (CCR) and effluent limitation guidelines (ELG), and its proposed decision to convert the Welsh plant to operate on gas.

We found that SWEPCO incurred $153 million and $144 million in net losses relative to the market value of energy and capacity at Flint Creek and Welsh respectively over the time period 2015 – 2020. Further, we found that the Company is projected to incur $161 million and $266 million at Flint Creek and Welsh, respectively, over the next decade (2021-2030). The Company’s decision to invest in CCR and ELG retrofits at Flint Creek is imprudent, as is its proposed decision to convert Welsh to operate on gas.

We recommended that the Commission disallow all operation, maintenance, and capital costs from test year base rates for Flint Creek and Welsh on the basis that SWEPCO has not demonstrated that it is prudent to continue investing in and operating these plants. Further, the commission should find that the Company’s decision to invest in CCR and ELG retrofits at Flint Creek was imprudent and disallow recovery of costs now and in the future that would be avoided through the retirement of Flint Creek by 2028. Finally, SWEPCO should not allow recovery of Welsh conversion costs without robust analysis justifying the conversion. 

Related Publication(s)
Redacted Testimony of Devi Glick Regarding SWEPCO's Application to Change Rates
Client:
Sierra Club
Year:
2021, 2020

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.

Related Publication(s)
Comments in Response to Otter Tail Power's 2021 Compliance Filing
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
Client:
Rhode Island Office of Energy Resources
Year:
2021

Working with the Cadmus Group, Synapse assisted the Rhode Island Office of Energy Resources in conducting an analysis of carbon pricing policies focused on the transportation and building sectors. Synapse led quantitative modeling of policy options, including both the impact of carbon prices on consumer adoption of electric vehicles and heat pumps and the impact of incentives or other programs funded by revenue from the carbon price. Synapse used our EV-REDI and Building Decarbonization Calculator tools to model stock turnover and the resulting emissions and energy use impacts. We also evaluated the economic impact of each carbon pricing policy option using IMPLAN, and health impacts using EPA's COBRA model.

View the carbon pricing study here.

Client:
Conservation Law Foundation
Year:
2021

Synapse is providing expert assistance to the Conservation Law Foundation in regard to Massachusetts Department of Public Utilities (DPU) docket 20-80. The Massachusetts DPU opened docket 20‐80 to examine the role of Massachusetts gas local distribution companies in helping the Commonwealth to achieve its 2050 climate goals. The DPU’s order requires the state’s gas utilities to complete studies over the next year that will inform this examination and allow the DPU and other state agencies to develop the specific roadmap to required emission reductions. 

Synapse produced the white paper below which presents a set of criteria for the required “future of gas” studies and has been submitted to docket 20-80. These criteria are designed to ensure that the studies will present sufficient, detailed, and justified data, analysis, and recommendations to inform the DPU and relevant stakeholders.

Related Publication(s)
Scoping a Future of Gas Study
Client:
Energy and Resource Solutions, Efficiency Maine
Year:
2021

The Efficiency Maine Trust (EMT) engaged Synapse, as a subcontractor to ERS, to develop statewide avoided transmission and distribution (T&D) costs in dollar per kilowatt-year. The avoided T&D costs were developed for the purpose of calculating the avoided costs associated with behind-the-meter energy efficiency and other demand-side measures. These were developed for use in benefit-cost testing of EMT's programs and will be included in the methodology and assumptions for EMT’s Triennial Plan IV for FY2020–FY2022.

Client:
Natural Resources Defense Council
Year:
2021

The Natural Resources Defense Council retained Synapse to provide technical and policy support for public comments on fossil gas forecasting methodologies in Nevada. With assistance from subcontractor John Rosenkranz, Synapse assessed the filings of NV Energy and Southwest Gas with the Public Utilities Commission of Nevada, and developed recommendations for better accounting of uncertainties, such as the impacts of electrification.

Related Publication(s)
NRDC Comments to the Public Utilities Commission of Nevada Docket No. 19-12019
Client:
Natural Resources Defense Council
Year:
2021, 2020

On behalf of the Natural Resources Defense Council, Synapse provided technical and policy support in a number of New York Public Service Commission (NY PSC) and Pennsylvania Public Utility Commission (PUC) proceedings.

In the 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. Separately, Synapse developed intermediate and long-term benchmarks for heating electrification to ensure that the State of New York is on a path to meet its net zero greenhouse gas emissions goal by 2050. Synapse also developed a white paper on the planning practices necessary to guide and support the transition from today’s fossil gas utility industry to one that complies with the emission requirements of New York’s Climate Leadership and Community Protection Act (CLCPA), supports the equitable distribution of energy-related benefits and burdens, maintains essential energy services, manages costs, and protects all customers. In a joint filing with other stakeholders, NRDC filed the Synapse white paper in the NY PSC’s ongoing proceeding to consider changes to gas utility planning and procedures in light of the policy changes facing the industry.

In Pennsylvania, Synapse submitted testimony on the Act 129 Energy Efficiency and Conservation plans of PPL Electric Utilities Corporation and PECO Energy Company. Also in Pennsylvania, Synapse assisted NRDC with developing comments for the PUC's proceeding on Utilization of Storage Resources as Electric Distribution Assets.

Related Publication(s)
Direct Testimony of Alice Napoleon and Kenji Takahashi regarding Niagara Mohawk’s proposed earnings adjustment mechanisms
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
New York Heat Pump Trajectory Analysis
Client:
Midwest Energy Efficiency Alliance
Year:
2021

In recent years, several Midwestern states have adopted or proposed policies with substantial impacts on the effectiveness of ratepayer-funded energy efficiency programs. Some of these states are restricting their programs through regulatory orders and legislative actions by limiting funding, repealing efficiency standards or targets, exempting large business customers, or failing to adopt progressive proposals on energy efficiency policies.

On behalf of the Midwest Energy Efficiency Alliance, Synapse Energy Economics assessed the impacts of recently adopted or proposed energy efficiency policies for six selected Midwestern states, namely Illinois, Indiana, Iowa, Missouri, Ohio, and Wisconsin. Our analysis found the adoption of these regressive policies (or the failure to adopt progressive policies) results in substantially large, missed opportunities to provide multiple benefits for the region. The benefits we analyzed in this study include reduced energy use, energy bill savings, reduced emissions from greenhouse gases and other pollutants, reduced health care costs, and new jobs.

Related Publication(s)
Missed Opportunities: The Impacts of Recent Policies on Energy Efficiency Programs in Midwestern States
Client:
Nova Scotia Utility and Review Board
Year:
2021

On behalf of Counsel to the Nova Scotia Utility and Review Board, Synapse analyzed and developed evidence regarding Nova Scotia Power’s (NS Power) proposed time-varying rate application. Synapse witness Melissa Whited recommended that the Board approve NS Power's proposed time-of-use and critical peak price tariffs and recommended that other aspects of the proposal be modified or rejected. In particular, Ms. Whited's evidence critiqued NS Power's proposed "Soft Launch" approach as failing to include adequate details regarding customer engagement strategy, as well as providing insufficient planning for evaluation, measurement, and verification. In addition, Ms. Whited found the company's lost revenue adjustment mechanism to be flawed and unnecessary, and certain tariff requirements to be overly restrictive. Finally, Ms. Whited's evidence pointed to the need to better incorporate long-run marginal costs into future tariff modifications.

Related Publication(s)
Evidence of Melissa Whited regarding NS Power application for time-varying rate tariff
Client:
Center for Energy and Sustainable Development at the West Virginia College of Law
Year:
2021

On behalf of the Center for Energy and Sustainable Development at the WV College of Law, Synapse modeled the accelerated retirement of the APCo and Mon Power coal-fired power plants located in West Virginia. We examined differences in customer costs, emissions, and economic benefits between two scenarios: one that continued to operate the units until 2040 and one that retired them no later than 2028. Synapse's analysis found early retirement of these coal-fired plants lowered costs, reduced greenhouse gas emissions, and created economic benefits for the citizens of West Virginia.

Related Publication(s)
West Virginia's Energy Future: Built Back Better
Client:
Union of Concerned Scientists
Year:
2021

The Union of Concerned Scientists hired Synapse to conduct an analysis of wind supply in Southwest Power Pool, motivated by the understanding that wind is being curtailed during hours with potentially displaceable coal generation. The analysis examines issues of wind oversupply, wind curtailment, and the relationship between wind curtailment and coal generation. The aim of this analysis is to characterize when wind curtailment is taking place, how much curtailment has occurred historically, and how curtailing coal generation instead of wind can provide more value to the region in terms of reduced greenhouse gas emissions from coal plants and reduced costs to ratepayers.

Related Publication(s)
Analysis of Wind Curtailment in Southern Power Pool 2018–2019
Client:
Year:
2020

Synapse presented two papers at the 2020 ACEEE Summer Study on Energy Efficiency in Buildings conference:

  1.  Kenji Takahashi presented a paper on a survey that examined various U.S. state and local building decarbonization policies and programs. This paper identifies the importance of overarching GHG emission targets and building electrification, the role of different policies targeting new vs. existing buildings, important synergies between clean energy supply policies and building demand policies, the role of municipal leadership, the need for program coordination, and the importance of addressing equity issues.
  2. Asa Hopkins presented a paper entitled "Keep Warm and Carry on: Electrification and Efficiency Meet the 'Polar Vortex'" which examines the hypothetical future case of universal building decarbonization through electrification when exposed to a “polar vortex” weather event, modeled on the event that spread from the Upper Midwest through New England in January 2019.
Related Publication(s)
Survey of U.S. State and Local Building Decarbonization Policies and Programs
Keep Warm and Carry On: Electrification and Efficiency Meet the “Polar Vortex”
Client:
Maryland Office of People’s Counsel
Year:
2020

Synapse was retained by the Maryland Office of the People's Counsel (OPC) to provide technical support for alternative ratemaking proceedings, with a focus on multi-year rate plans (MRPs). Per Maryland Public Service Commission Order No. 89226, a Working Group was established to develop an implementation report for MRPs. Synapse assisted OPC by helping develop positions, drafting comments and rebuttal comments, and attending workshops. Our focus was on the overarching design of MRPs to ensure that they operate in the public interest, provide proper incentives to utilities, and mitigate information asymmetries. Our work included methods for setting allowed annual revenue requirements, the design of earnings sharing mechanisms, operation of any reconciliation mechanisms, specifying utility reporting requirements, and proposing accompanying planning processes. 

Client:
National Parks Conservation Association
Year:
2020

On behalf of the National Parks Conservation Association (NPCA), Synapse prepared a report and briefed stakeholders and relevant parties on its its findings regarding Dominion's need for the Surry-Skiffes Creek 500 kV Transmission Line that was constructed across the Jamestown River.

In this report, we review Dominion and the U.S. Army Corps of Engineers’ justification for the Surry-Skiffes Creek-Whealton project, evaluate the actual level of need in the NHRLA, and develop a set of alternative portfolios that can meet area need and comply with North American Electric Reliability Corporation (NERC) requirements without the Surry-Skiffes Creek project. We recommend that in the upcoming Environmental Impact Statement, the U.S. Army Corp of Engineers should require that Dominion evaluate modular battery storage as a new supply option, and update its load forecast.

Related Publication(s)
Alternatives to the Surry-Skiffes Creek 500 kV Transmission Line
Client:
District of Columbia Department of Energy and Environment
Year:
2020, 2019

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.”

Related Publication(s)
DCG Comments on Technical Conference III Regarding F.C. 1156
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

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