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.
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Synapse presented two papers at the 2020 ACEEE Summer Study on Energy Efficiency in Buildings conference:
- 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.
- 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.
Keep Warm and Carry On: Electrification and Efficiency Meet the “Polar Vortex”
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.
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.
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 the Eastern Environmental Law Center (EELC), Synapse and subcontractor John Rosenkranz conducted a comprehensive assessment of National Grid’s Capacity Report released February 24, 2020. National Grid's Capacity Report detailed gas peak demand forecasts through the winter of 2034/35, modeling both High Demand and Low Demand scenarios. The report then assessed various long-term gas solutions to fill these gaps. These potential solutions included various large-scale gas infrastructure projects such as the NESE pipeline and LNG facilities, as well as a “No Infrastructure” option which solely relies on additional demand-side resources.
Our analysis found various errors in National Grid’s assessments of the rate of customer conversion from oil to natural gas for the load forecasts, expected levels and costs of energy efficiency and heat pumps under existing or expanded policies and programs, and gas supply resources. The report concludes that corrections to these errors and appropriate treatment of demand-side measures, with or without small changes in National Grid’s supply planning assumptions, eliminates the need for any of the large-scale infrastructure investments examined in the Capacity Report.
On behalf of the DC Department of Energy and Environment (DOEE), Synapse reviewed the Climate Business Plan (CBP) that Washington Gas Light and AltaGas filed to comply with merger conditions in Washington, DC. We assisted DOEE in drafting comments and reply comments on this filing, with particular emphasis on the shortcomings of the filed CBP as a "business plan" that showed how the gas company could transition its business model to be consistent with carbon neutrality.
Synapse participated in a series of workshops on behalf of the Public Counsel Unit of the Washington Attorney General designed to update Avista's methodology for updating its calculations of power costs.
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.
On behalf of Environmental Defense Fund, Synapse conducted a benefit-cost analysis of proposed emissions rules drafted by the New Mexico Environment Department. These proposed rules curb emissions of volatile organic compounds (VOCs) from the oil and gas industry in New Mexico. The analysis compared implementation costs to four types of benefits to the state of New Mexico: sales from newly captured gas, avoided costs related to human health impacts, avoided nonattainment costs of reduced GHG emissions, and the global societal benefit of reducing methane emissions into the atmosphere. The report presents three different approaches to the benefit-cost ratio (BCR) of the proposed rules (e.g., New Mexico BCR, National BCR, and Global BCR) – all of which are cost-effective according to the Synapse analysis.
On behalf of the Natural Resources Defense Council, Synapse is providing technical and policy support in a number New York Public Service Commission (PSC) proceedings, including the Reforming the Energy Vision (REV) initiative. This work includes review, comments, and analysis of policies and targets for energy efficiency and other distributed energy resources, to ensure that New York meets its climate, energy, and low- and moderate-income energy affordability goals. Project ongoing.
The 100PercentCT Project developed by People’s Action for Clean Energy (PACE) supports the transition to a clean energy economy in Connecticut. The project’s primary function is to conduct energy analyses to help inform individual towns and the State of Connecticut about opportunities to achieve 100 percent renewable energy for the buildings and transportation sectors. PACE developed the Town Energy Analysis model—an in-house, techno-economic tool—to inventory energy use and emissions in Connecticut towns and evaluate strategies to transition to renewable energy.
Synapse performed an in-depth review of PACE’s Town Energy Analysis model to identify opportunities to improve upon and expand the model. We evaluated the modeling methods, sectors, and scope included in the energy analysis, as well as the inputs and data sources used. We compared PACE’s model alongside 10 publicly available energy and climate modeling tools to identify opportunities to align the Town Energy Analysis model with current best practices in energy and greenhouse gas accounting and in identification of mitigation opportunities.
Synapse issued a report to PACE presenting our review of the Town Energy Analysis model. First, our report summarizes the energy and climate modeling tools used to establish current energy and climate planning best practices for analytical models. Next, we validate PACE’s model and identify specific changes to improve key data, inputs, methods, and assumptions used in the model. We conclude by identifying additional modeling approaches, clean energy strategies, market segments, and energy impacts for the possible inclusion within PACE’s Town Energy Analysis model.
Synapse supported the Natural Resources Defense Council (NRDC) with analysis of a commercial electric vehicle time-of-use (TOU) rate that was proposed by Duquesne Light in Pennsylvania in a regulatory proceeding. Synapse calculated bill impacts for small and medium commercial and industrial (C&I) customers, aiming to understand how charging non-EV load on the EV TOU rate impacts the bills of C&I customers, relative to the default flat rate. Synapse also compared the impact of the TOU rate on EV charging cost per mile relative to the cost of gasoline per mile for a comparable internal combustion engine vehicle. The analysis examined several types of small and medium C&I customers, including hotels, office buildings, and warehouses, as well as DC fast-charging load. The final deliverable was a slide deck that was used as an exhibit in NRDC's testimony. The testimony is filed here.
Synapse, subcontracting to Eastern Research Group, supported the Maine Climate Council in modeling economy-wide decarbonization pathways for the state that met the state’s goal of reducing emissions by 45 percent by 2030 and 80 percent by 2050 below 1990 levels. Synapse analyzed the transportation, buildings, and electric power sectors using its suite of electrification and decarbonization models. Synapse used its EV-REDI and Building Decarbonization Calculator (BDC) tools to determine trajectories for the adoption of non-emitting electric vehicles (EV) and heat pumps needed to reduce emissions in line with the state’s 2030 and 2050 targets. Using these models, we also calculated the resulting electricity consumption, which we used as an input into the electric sector modeling to ensure that enough clean energy would be generated to meet the growing needs of an electrified economy. Synapse used the EnCompass model to develop a scenario in which Maine’s renewable portfolio standard increased to 100 percent by 2050. Synapse also evaluated reasonable emissions reduction trajectories in other sectors of the economy. The resulting analysis illustrated some of the tradeoffs between reducing emissions through different technological pathways. Synapse energy sector modeling informed the Maine Climate Council's recommendations published in the final report "Maine Won't Wait: A Four-year Plan for Climate Action."
On behalf of Sierra Club, Synapse submitted testimony supporting electric system transformation within an APS rate case, including support for enhanced customer access to data, opposition to formula rates, and recommendations for evaluation of securitization.
Surrebuttal Testimony of Cheryl Roberto for Docket No. E-01345A-19-0236
As a continuation of previous work, Synapse provided counsel to the NS UARB with technical consulting services on demand side management (DSM) issues. As part of the project, Alice Napoleon submitted evidence on EfficiencyOne?s proposed 2020-2022 Demand Side Management Resource Plan. In addition, Synapse reviewed, conducted analysis, and provided comments on the following issues: improving the accuracy of energy savings and spending projections; modeling DSM rate and bill impacts; assessing DSM potential in the province; designing a program to target DSM at locations where distribution system investment can be avoided; and modeling avoided transmission and distribution system costs.
Synapse Comments on EfficiencyOne Performance Alignment Study - M09096
Synapse Comments on EfficiencyOne's 2019 Rate and Bill Impact Analysis and Model - M09471
A 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.
The FERC approved the Atlantic Coast Pipeline (ACP) in 2017. Project owners Duke and Dominion filed a certificate for a construction extension with FERC on June 16, 2020. On behalf of the Southern Environmental Law Center, Synapse assessed the projected demand for new gas used for electric generation, estimating the “maximum demand for new gas” on a peak winter day in Dominion’s and Duke’s service territories. We examined public IRPs, new policies in Virginia and North Carolina that will lower CO2 emissions in the electric sector, and public documents related to the utilities’ internal emission reduction goals. We used that data to build spreadsheet models to assess maximum future gas demand on a winter peak day. Our analysis demonstrates that the need for new gas-fired generating resources originally anticipated by Duke and Dominion has not and will not materialize, thus negating the utilities’ claimed need for the ACP.
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
Synapse was retained by the Sierra Club to evaluate how coal unit commitment decisions by Monongahela Power Company in West Virginia have impacted ratepayer costs over the two-year period beginning July 1, 2018 and ending June 30, 2020. The results of this analysis were presented in testimony before the West Virginia Public Service Commission.
Synapse is assisting Energy Outreach Colorado in responding to Public Service Colorado’s time-of-use (TOU) rate implementation proposal. TOU rates have the potential to provide customers with greater control over their bills and reduce system costs. However, to be successful, TOU rates must be implemented thoughtfully and with sufficient customer education, protections, and choice. Synapse’s testimony focuses on best practices for implementing TOU rates and particularly for ensuring that low-income customers are adequately protected and are not subject to rates that would be disproportionately burdensome.
Cross-Answer Testimony and Attachments of Tim Woolf Regarding Need for Customer Opt-Out Provision in PSCo's TOU Rate Plan
Nova Scotia Power Inc (NSPI) filed a capital work order application for recovery of $7.1 million in costs associated with implementing a pilot study using an energy system platform to manage the impacts of Distributed Energy Resources, including paired solar and storage, community solar, and electric vehicle charging. Synapse filed testimony addressing the design and objectives of the pilot and NSPI's assessment of risk.
Synapse was retained to review applications by Indiana electric utilities to recover “lost revenue” resulting from lower than expected commercial and industrial sales due to COVID-19. Synapse's expert witness Cheryl Roberto recommended no recovery of lost revenue to The Indiana Utility Regulatory Commission. The Commission ultimately ruled against recovery of lost revenue; consistent with Synapse recommendations.
Synapse was retained by Sierra Club to review a request by Evergy Metro, Inc. and Evergy Missouri West, Inc. to recover “lost revenue” resulting from lower than expected commercial and industrial sales due to COVID-19. Synapse expert witness Cheryl Roberto testified before The Missouri Public Service Commission, recommending no recovery of lost revenue.
Synapse assisted the Sierra Club with evaluating Dominion’s 2020 Virginia IRP and modeling alternative scenarios demonstrating the cost effectiveness of clean energy generation and coal retirements. Synapse modeled an optimized Virginia Clean Economy Act (VCEA) compliant scenario in EnCompass that resulted in lower emissions and lower costs than Dominion’s preferred plan. Rachel Wilson sponsored testimony describing how the Synapse scenario eliminated unnecessary gas capacity additions that Dominion fixed in its modeling, and showed that accelerating retirements of certain coal units by increasing solar generation capacity would save ratepayers billions of dollars. In addition, Synapse reviewed Dominion’s position regarding the PJM Minimum Offer Price Rule (MOPR) and the Fixed Resource Requirement (FRR) alternative to participating in the PJM capacity market under the MOPR. Jason Frost sponsored testimony describing how the MOPR will increase the costs of meeting state clean energy goals and require Dominion to retain unnecessary legacy fossil fuel powered generation by not counting renewable capacity. Mr. Frost’s testimony also discusses how the FRR presents a way to avoid the negative impacts of the MOPR, and can reduce consumer costs by avoiding the need to pay for legacy fossil fuel capacity that is no longer needed.
Direct Testimony of Jason Frost in Case No. PUR-2020-00035
Synapse provided expert testimony and analysis to support Sierra Club in reviewing Wisconsin Power and Light (WPL) and Madison Gas and Electric’s (MGE) Fuel Cost Plans for 2021. Synapse’s testimonies focused on reviewing the operational practices used by MGE and WPL at the companies' coal-fired power plants at the Columbia Energy Center and Elm Road Generating Station. We also evaluated the plants' recent economic performance and discussed the risks these uneconomic unit commitment practices pose to MGE and WPL’s ratepayers. We found that the companies have not historically used price-based unit commitment process either in practice or in developing their annual fuel cost plans and that the current fuel planning process anticipates and enables uneconomic unit commitment by the companies.
We recommended that the companies be required to model their units operating economically for planning purposes, and to refresh their current plants to reflect this assumption. Further, we recommended that the companies be required to economically commit their units into the market, or otherwise to document their unit commitment decision-making process. Finally, we recommended that the Public Service Commission of Wisconsin make clear to utilities that their unit commitment practices will be subject to prudence reviews in the future reconciliation dockets.
Direct Testimony of Devi Glick in the application of WPL for approval to extend rates and for its fuel cost plan
Surrebuttal Testimony of Devi Glick in the application of WPL for approval to extend rates into 2021 and its fuel cost plan
Surrebuttal Testimony of Devi Glick in the application of MGE for authority to change electric and natural gas rates
The Maryland Office of People’s Counsel retained Synapse to provide expert witness testimony on the multi-year rate plan proposed by Baltimore Gas and Electric (BGE).
Surrebuttal Testimony of Cheryl Roberto regarding BGE's application for an electric and gas multi-year plan
The Sierra Club retained Synapse to provide expert testimony in Georgia Power Company’s 2019 general rate case. Several matters were at issue in this case, and Synapse was tasked with addressing the Company’s proposal to recover the expenses of coal ash remediation and its request to increase the residential customer fixed charge.
The Maryland Office of People’s Counsel retained Synapse to provide expert witness testimony on the benefit-cost analysis Baltimore Gas and Electric Company filed for its electric vehicle program portfolio as part of its Multi‐Year Plan. Synapse was also retained by OPC to respond to a benefit-cost analysis on the Potomac Electric Power Company's electric vehicle programs.
Surrebuttal Testimony of Courtney Lane Regarding BGE's Benefit-Cost Analysis of EV Programs
Direct Testimony of Courtney Lane in Reviewing PEPCO's Benefit-Cost Analysis of EV Programs
Surrebuttal Testimony of Courtney Lane Regarding Pepco's Benefit-Cost Analysis of EV Programs
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