Synapse is assisting this group of consumer and environmental advocates with their goal of reducing future transmission costs in New England. Topics will include: (a) properly accounting for energy efficiency in forecasting loads for transmission planning, (b) properly accounting for non-transmission alternatives in transmission planning, (c) participating in ISO-New England’s Strategic Initiative, and (d) providing input to the New England Regional System Plan. This work includes participating in a variety of different forums, including FERC dockets, ISO-NE stakeholder processes, NEPOOL technical committees, and discussions with a variety of New England stakeholders. The E4 Group is composed of the Maine Office of the Public Advocate, Grid Solar, Environment Northeast, Conservation Law Foundation, and Maine Industrial Energy Consumers.
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Challenges for Electric System Planning
2016 NECPUC Symposium Presentation
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 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 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.
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 conducted analysis and provided comments on proposals to modify the DSM rate and bill impact model, to develop a methodology for calculating avoided transmission and distribution system costs, and to design a program to target DSM at locations where distribution system investment can be avoided. Synapse also analyzed and critiqued a DSM potential study, and an analysis of potential bias in the program administrator's projections of energy savings and spending.
Synapse Comments on EfficiencyOne Performance Alignment Study - M09096
Synapse Comments on EfficiencyOne's 2019 Rate and Bill Impact Analysis and Model - M09471
A new 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.
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 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
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 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 Commission. The Commission ultimately ruled against recovery of lost revenue; consistent with Synapse recommendations.
The Maryland Office of People’s Counsel (OPC) retained Synapse to provide expert witness testimony on the benefit-cost analysis (BCA) Baltimore Gas and Electric Company (BGE) filed for its electric vehicle program portfolio as part of its Multi‐Year Plan.
Surrebuttal Testimony of Courtney Lane in Case No. 9645
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 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.
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.
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
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 is providing 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
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