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.
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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 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 of Courtney Lane Regarding BGE's EV Program
Direct Testimony of Courtney Lane in Reviewing PEPCO's Benefit-Cost Analysis of EV Programs
On behalf of the Natural Resources Defense Council, Synapse prepared a sweeping analysis and developed recommendations for New York to consider as the state begins a transition away from natural gas in order to meet its ambitious carbon reduction requirements. The report is being filed in the New York Public Service Commission's recently opened natural gas planning process docket.
This report is part of Synapse's continued support for New York State's "Reforming the Energy Vision" (or "REV") initiative. Find more of Synapse's work completed on behalf of NY REV here.
Electricity generation from Duke Energy, Dominion Energy, and Southern Company utilities collectively represent 12.4 percent of U.S. power sector CO2 emissions – equivalent to 4.2 percent of total U.S. CO2 emissions. While all three utilities have announced plans to decarbonize their electricity generation by 2050 in order to meet climate targets, a deeper look into their generation portfolios and plans reveals that all three utilities are on track to fall short of their emissions reduction commitments.
On behalf of the Climate Majority Project, Synapse investigated the companies’ current plans for fleet decarbonization. We made the following recommendations to help ensure a path to reach climate targets by 2050: (1) develop science-based CO2 trajectories upon which all future plans and actions should be rooted; (2) conduct robust retirement and replacement analysis to determine the least cost path to retire each company’s existing fossil fleet and replace it with alternative zero-carbon portfolios; (3) invest in renewables and demand-side resources to meet future resource needs; (4) invest in grid-modernization solutions in tandem with retirement of existing resources and development of renewables; and finally (5) evaluate and plan for changing system needs, including load growth driven by electrification instead of traditional steady demand.
Synapse worked on behalf of Labor Network for Sustainability to analyze the economic benefits of improving energy, water, and transportation infrastructure in Massachusetts through increased state, municipal, and public investment. First, we identified spending gaps between existing investment plans for these three sectors and the level of investment needed to bring the sectors to a state of good repair. We used infrastructure needs reports, gap analysis studies, and state policy goals to identify the spending gaps. Next, we calculated the employment impacts of improving this infrastructure through increased investment between 2020 and 2030. We used IMPLAN, an industry-standard job impact model, to convert annual spending levels into annual job creation. We produced a final report summarizing the results for all three sectors as well as a selected set of city-specific case studies.
Engaged by Apogee Climate and Energy Transitions, Synapse reviewed the publicly available documents associated with the Kentucky Municipal Energy Agency’s 2020 integrated resource plan process. Synapse provided the client with a memo detailing its concerns with KYMEA’s IRP process, its forecast, capacity and energy obligations, contractual options, and provided short-, medium-, and long-term recommendations. Dr. Thomas Vitolo provided public comments to KYMEA on September 24, 2020.
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
On behalf of the Sierra Club and Natural Resources Defense Council, Synapse provided technical support and expert witness testimony in California docket A19-11-019. Synapse conducted a bill impacts analysis for customers in three different climate zones who might electrify their home on Pacific Gas & Electric's proposed E-ELEC time-of-use rate. Erin Camp, PhD, authored expert witness testimony, demonstrating that electrifying on the proposed E-ELEC rate is not likely to be economical for customers who live in multi-family buildings, especially those customers who are low-income. In her testimony, Dr. Camp advocated for a separate, additional electrification time-of-use rate for all low-income customers in PG&E's service territory to alleviate the barrier to electrifying for this vulnerable customer group.
This project is ongoing and is currently in settlement discussions.
The Maryland Public Utilities Article (“PUA”) § 7-216 established the Maryland Energy Storage Pilot Program. The pilot program required each distribution utility to submit at least two energy storage project applications for Commission review. Synapse was retained by the Maryland Office of People's Counsel to assist with reviewing the applications and to provide technical analysis and recommendations. With Synapse’s assistance, OPC prepared extensive discovery requests for each of the four utilities, seeking information and data on their energy storage applications.
Synapse thoroughly reviewed each pilot energy storage project application. The review included an assessment of the proposed projects in three general areas. Synapse's Courtney Lane led the economic and ratemaking analysis of the projected costs, savings, and benefits of the proposed projects. Dr. Erin Camp led the assessment of environmental impacts and Dr. Steve Letendre addressed wholesale market issues. Synapse analysis raised concerns about wholesale market revenue risks, deferral value calculations, and emissions impact methods. Synapse expert witnesses participated in the Maryland Public Utilities Commission hearing held on July 13, 2020, to present to the Commission Synapse's analysis of the storage project applications.
The Massachusetts Department of Energy Resources retained Synapse and subcontractor DNV GL to produce a comprehensive assessment of mobile energy storage systems and their use in emergency relief operations. The study explored the landscape of available mobile energy storage systems, which are roughly divided into towable units and self-mobile systems in the forms of various electric vehicle (EV) platforms. Mobile energy storage systems may be uniquely capable of enhancing energy resilience in response to severe weather events and associated outage conditions. The study found that mobile energy storage systems can be self-mobile electric vehicles (light-duty vehicles, vans, or buses) or towable (towable or transportable via semi-trailer truck). This study provided a comprehensive assessment of mobile energy storage systems, their use in emergency relief operations, and their use on typical (non-outage) days. Specifically, this report addressed four fundamental questions: state-of-the-art, usage on typical days, opportunities and challenges to deploy in response to outages, and potential advantages over stationary battery energy storage systems.
The final report, Mobile Energy Storage Study: Emergency Response and Demand Reduction, is available on the Department of Energy Resources website.
Synapse worked for the National Efficiency Screening Project (NESP) with E4TheFuture as coordinator to develop a National Standard Practice Manual for Benefit-Cost Analysis of Distributed Energy Resources (NSPM). The purpose of the NSPM is to improve the way that utility customer-funded distributed energy resources are evaluated for cost-effectiveness throughout the United States, and to inform decision-makers regarding which resources are in the public interest and what level of investment is appropriate. The NSPM provides a set of policy-neutral, unbiased, and economically sound principles, concepts, and methodologies to support benefit-cost analysis for distributed energy resources, including: energy efficiency, demand response, distributed generation, distributed storage, and building and transportation electrification. Synapse's primary role was as the lead technical consultant. The manual was developed with a Drafting Committee of five experts and incorporated input from a nation-wide Review Committee. The NSPM is available here.
Using hourly, publicly available data, Synapse examined the impact of solar on energy benefits. From 2014-2019, behind-the-meter solar created $1.1 billion in energy benefits in the six New England states. These include savings resulting from purchasing less electricity, as well as savings due to lower overall electricity prices. We estimate that solar contributed to $87 million in public health benefits, and reduced CO2 emissions by 4.6 million metric tons, equivalent to taking one million cars off of the road.
Synapse provided expert advice on and analysis of energy efficiency programs offered by New Jersey's Clean Energy Program for the New Jersey Division of Rate Counsel. We reviewed, analyzed, and commented on various energy efficiency-related matters, including the state-administered programs’ designs and budgets, avoided energy supply cost estimates, cost-benefit analyses, energy savings protocols updates, and fiscal year budget proposals. We also reviewed and commented on New Jersey Energy Master Plans, a three-year energy efficiency program plan called the Comprehensive Resource Analysis, and various proposals associated with the new energy efficiency program framework including program delivery structure, program design, performance incentives, and cost recovery.
Of all U.S. states, Florida will feel the largest direct impacts from climate change. Given the City of Orlando’s vulnerability to climate impacts, Mayor Dyer and Orlando City Commissioners commitment to 100 percent renewable energy by 2050 was a critical move. Yet Orlando’s electric utility, the Orlando Utilities Commission, still relies almost entirely on fossil fuels to supply the City’s electricity. The City is currently conducting an integrated resource planning exercise to determine the future of its electricity system; this study focuses strongly on fossil resources and includes an evaluation of whether to keep the Stanton Energy Center online, convert the units to gas, or retire the plant. In response to the utility’s IRP exercise, Synapse conducted a study on behalf of the First 50 Coalition to evaluate an alternative renewable and clean energy portfolio that can provide the City with the energy and capacity it needs at a lower cost and lesser environmental impact than the fossil heavy system that the City’s IRP will propose.
National Grid commissioned Synapse to develop a Microsoft Excel-based analytical model to assess the long-term rate and bill impacts of its Rhode Island energy efficiency natural gas programs. The model was designed to analyze annual and long-term rate and bill impacts from natural gas energy efficiency programs implemented over a course of three years. Synapse designed the model to analyze rate and bill impacts from natural gas energy efficiency programs in Rhode Island for four customer types: residential, income-eligible, small commercial, and large commercial and industrial (large C&I) and for each program contained within those categories. The model was designed for National Grid’s 2021–2023 Three-Year Energy Efficiency Program Plan and its 2021 Annual Program Plan, but it can be updated for subsequent prospective and retrospective analyses in assessing how the Plans meet the requirements for energy efficiency in Rhode Island.
Synapse is providing expert testimony and analysis to support Sierra Club in Duke Energy Indiana’s Fuel Adjustment Cost (FAC) dockets for the period of September 2019 through May 2020.
Synapse is evaluating the unit commitment and dispatch practices for Duke’s four coal plants at Edwardsport, Cayuga, Gibson, and Gallagher as part of the Company’s regular Fuel Adjustment Cost Adjustment (FAC) dockets. We find that Duke has been uneconomically committing most of its units a majority of the time throughout this entire time period. These commitment and dispatch practices were further exacerbated by the Company’s implementation of a fuel price decrement in FAC 125 (March – May 2020) to address the Company’s coal oversupply.
We find that as a result of the Company’s uneconomic commitment and dispatch practices, Duke has accumulated net revenue losses (based on just variable and fuel costs) at most or all of its units during at least one (and in most cases all) of the FAC 123, FAC 124, and FAC 125 periods between September 2019 and May 2020. As a result of our work in FAC 123, the Indiana Utility Regulatory Commission agreed to open a subdocket to examine the issue of unit commitment more closely. Synapse has provided expert support and testimony in all three FAC periods as well as the subdocket.
Cause No. 38707-FAC123 Devi Glick Exhibits 1 through 5
Cause No. 38707-FAC123 Devi Glick Exhibits 6 and 7
Direct Testimony of Devi Glick in Cause No. 38707-FAC124
Cause No. 38707-FAC124 Devi Glick Exhibit 1
Cause No. 38707-FAC124 Devi Glick Exhibit 2
Cause No. 38707-FAC124 Devi Glick Exhibits 3 and 4
Direct Testimony of Devi Glick in Cause No. 38707-FAC125
Direct Testimony of Devi Glick in Cause No. 38707-FAC123 S1
On behalf of the Rhode Island Office of Energy Resources (OER), Synapse conducted a geospatial analysis to determine an estimate of the likely solar potential available within a number of solar siting categories. Synapse examined and quantified solar potential for the following six siting categories:
-Rooftop solar (including rooftops of residential single family, residential multifamily, commercial, industrial, municipal, and other building types)
-Ground-mounted solar in the following four categories: (1) Landfills, (2) gravel pits, (3) brownfields, and (4) commercial and industrial developed and undeveloped lots
-Parking lot / carport solar
We used geospatial analysis to examine the following types of potentials for each category of solar:
-Total Potential, an estimate of the solar potential for the entire area under consideration, with no exceptions.
-Technical Potential, an estimate of the potential excluding areas not suitable for solar development. These challenges may reduce technical potential, relative to total potential.
For residential rooftop solar, we also analyzed:
-Economic Potential, an estimate of the solar potential that is likely to be installed, given the current cost of the technology, the current financial incentives available, and the household economics specific to a municipality. This potential category was analyzed for residential rooftop solar only.
In addition, for each category of solar, we compiled estimates of these MW potentials translated into gigawatt-hour (GWh) generation potential, solar costs (based on costs available as of late 2019 / early 2020), avoided greenhouse gas emissions, and possible impacts on distribution system hosting capacity.
Solar Siting Opportunities for Rhode Island: Slide Deck
Synapse provided expert witness testimony and analysis to Sierra Club for Southwestern Public Service Company's (SPS) 2019 rate case in the states of New Mexico and Texas. The case focused on the retirement date for the Tolk Plant, which the Company was requesting be moved up based on a water shortage in the region that would limit the ability for SPS to continue economically operating the plant year-round through its current retirement date. Synapse’s testimony and analysis focused on both the recent historical and future projected economic performance of Tolk under the Company’s proposed seasonal operations plan for the plant moving forward. We also evaluated the Harrington Coal-fired Power Plant. We found that both plants are likely to lose money going forward relative to alternatives and the market, and therefore SPS should develop a plan to retire both plants. SPS has been required to update its analysis on the future operation of the Tolk Power Station.
Testimony of Devi Glick in Case No. 19-00170-UT
Direct Testimony of Devi Glick in PUC Docket No. 49831
Building decarbonization has been a growing focus for climate initiatives among local and state governments in the United States over the past several years. Such initiatives are often focused on building end-use electrification. They include (a) electrification codes for various building types and end-uses in new buildings, (b) building performance standards for existing, large commercial buildings, (c) new funding mechanisms to encourage fuel switching from fossil fuel-based heating to electric heat pumps, (d) modifications to energy efficiency program cost-effectiveness screening to encourage electrification, and (e) heating oil taxes to fund heat pump installations.
We reviewed 15 state and local jurisdictions for these policies and programs across the United States representing a range of different approaches. In this paper, we summarize key findings from this survey. We highlight the range of policy and program options that have been implemented, adopted, or are under development and the regulatory and policy mechanisms utilized. We also provide relevant context such as local policy, political culture, building energy use, and utility providers. In addition, our paper summarizes, where relevant, the opinions of various stakeholders expressed during the development of the local and state policies. Finally, based on these assessments, we identify barriers to and success factors for adoption of effective building decarbonization policies. This research offers a variety of cutting-edge policy and program options for state and local governments to consider adopting. The research can also help policymakers, advocates, and other stakeholders assess current and future progress toward building decarbonization policy and program development and implementation.
On behalf of the Natural Resources Defense Council, Synapse is providing technical and policy support in a number of New York Public Service Commission (NY PSC) and Pennsylvania Public Utility Commission (PUC) proceedings.
In the ongoing 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.
In Pennsylvania, Synapse submitted testimony on the Act 129 Energy Efficiency and Conservation plans of PPL Electric Utilities Corporation and PECO Energy Company. Separately, Synapse assisted NRDC with developing comments for the PUC's proceeding on Utilization of Storage Resources as Electric Distribution Assets.
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
Synapse prepared and sponsored expert witness testimony on issues related to the investor-owned utilities’ plans for their low-income energy efficiency programs (called the “Energy Savings Assistance Program” or "ESA") for the 2021-2026 period. The testimony made recommendations regarding program goals, depth of savings, cost effectiveness, addressing the mobile home segment, consideration of health and safety measures, review of pilot proposals, and consideration of long-lived fossil-fuel burning equipment. Synapse also participated in workshops and provided technical support with comments on the draft and final proposals of the Staff of the California Public Utilities Commission Energy Division, which set forth a vision and framework for the ESA program to ensure that participants realize greater energy bill savings.
Comments of The Utility Reform Network on the Energy Division Staff Proposal and Utility Applications
On behalf of the Office of the People's Counsel for the District of Columbia, Synapse performed a Ward-level analysis of three future solar scenarios for the 2019-2041 timeframe. Using geospatial and economic analysis, Synapse also calculated the likely mix of private and community solar for the District, as well as the likely mix of rooftop, parking lot, and ground-mount solar through the study period. Based on the scenarios developed, Synapse recommended courses of action to help the District meet its ambitious solar carve-out goal (10% in-District solar by 2041). Finally, Synapse conducted a rate impact assessment of each solar scenario to determine which has the best impact on ratepayers in the District. Synapse recommended the District government closely monitor progress of the solar installations relative to the carve-out, as benefits are greatest if compliance is achieved early in the study period.
Tucson Electric Power (TEP) filed a rate case with the Arizona Corporation Commission requesting approval to place into rate base its purchase of the Gila River Unit 2 natural gas combined cycle plant and its investments in ten new reciprocating internal combustion engine (RICE) units. Synapse experts Avi Allison and Devi Glick filed testimony on behalf of Sierra Club evaluating the prudence of these purchases and assessing the economics of TEP's remaining coal units.
Surrebuttal Testimony of Avi Allison in Docket No. E-01933A-19-0028
Response to Late-filed ACC Staff Testimony of Devi Glick in Docket No. E-01933A-19-0028
On behalf of the Maryland Office of the People's Counsel, Synapse is providing technical support and expert witness services in order to facilitate alternative ratemaking proceedings, with a focus on multi-year rate plans.
On behalf of the District of Columbia Department of Energy and Environment (DOEE), Synapse provided expert witness testimony regarding Pepco’s proposed multi-year rate plan and performance incentive mechanisms. Synapse also drafted comments in response to the Commission's Notice of Inquiry regarding implementation of the CleanEnergy DC Omnibus Amendment Act of 2018, which requires the Commission to consider the “effects on global climate change and the District’s public climate commitments.”
GD2019 04 M: DC DOEE Comments Responding to Notice of Inquiry
Direct Testimony of Courtney Lane in Formal Case No. 1156
Rebuttal Testimony of Courtney Lane in Formal Case No. 1156
Surrebuttal Testimony of Courtney Lane in Formal Case No. 1156
Supplemental Testimony of Courtney Lane in Formal Case No. 1156
On behalf of Earthjustice, Synapse reviewed the U.S. EPA's benefit-cost analysis of changes to the proposed power plant effluent limitations guidelines (ELG). Synapse created an expert report that Earthjustice submitted as part of its official comments on the proposed rule modification.
The purpose of this report is to (1) evaluate the proposed changes to the 2015 ELG rule; (2) review the four options the EPA lays out for compliance (focusing on Options 2 and 4); (3) review the EPA’s benefit cost analysis (BCA); (4) critique the EPA’s analysis and results; and (5) provide recommendations on how the EPA should structure its BCA and which compliance option it should recommend.
Synapse prepared a Technical Brief that provides an overview of benefit-cost analysis techniques for reviewing utility proposals for grid modernization investments. The Brief is written for regulators, consumer advocates, and other stakeholders who seek to determine whether grid modernization proposals are in the public interest; especially proposals for utility-facing technologies that help advance reliability, resilience, advanced metering, and the integration of distributed energy resources. The Technical Brief addresses some of the most challenging aspects of benefit-cost analysis for grid modernization, such as determining the appropriate cost-effectiveness test to use, accounting for interactive effects between grid modernization components, and accounting for qualitative benefits. Tim Woolf presented the material in a training course for consumer advocates at the meeting of National Association of Utility Consumer Advocates in November 2018. He also presented the material at the Mid-Atlantic Distribution Systems and Planning Training with the NARUC-NASEO Task Force on Comprehensive Electricity Planning on March 8, 2019. The technical brief was published in February 2021.
Benefit-Cost Analysis for Utility-Facing Grid Modernization Investments
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