In 2016, Public Service Company of Colorado (PSCo) filed a request for rate design modifications, including a tiered monthly “Grid Use Charge” for all residential customers and a voluntary residential demand – time-of-use rate. The Company’s stated intent for the proposed Grid Use Charge was to act as an interim step before the implementation of a demand charge. On behalf of Energy Outreach Colorado, Synapse conducted an analysis of PSCo’s proposal and Tim Woolf provided expert testimony before the Colorado Public Utilities Commission. Synapse’s testimony challenged the Company’s proposal to move residential customers toward demand charges because such charges are inconsistent with fundamental rate design principles, create inefficient price signals, are complex and difficult for residential customers to respond to, place undue burden on low-usage and low-income customers, and may ultimately increase long-term electricity costs. Project ongoing.
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In Maine, the Efficiency Maine Trust plans for and administers all energy efficiency programs across the state in an integrated fashion, including those funded from electric and natural gas ratepayers, in accordance with three-year plans that must be approved by the Maine Public Utilities Commission. Synapse assisted the Natural Resources Council of Maine in its review of the Trust’s 2014 plan for its first statewide natural gas energy efficiency programs by providing analysis and testimony regarding maximum achievable cost-effective (MACE) savings and budgets. Synapse also provided high-level input on implementation issues, gas conservation strategy, and planning best practices.
On behalf of the Natural Resources Council of Maine (NRCM) and the Conservation Law Foundation, Synapse provided technical support and expert testimony in the Maine Public Utilities Commission’s review of the Efficiency Maine Trust’s Triennial Plan for Fiscal Years 2017-2019. Synapse’s Tim Woolf submitted direct testimony that assessed the key assumptions used in the plan, reviewed the energy efficiency potentials used in preparing the plan, and assessed the plan’s likelihood of reaching the maximum achievable cost-effective (MACE) potential for gas and electricity customers. The testimony included recommended modifications for reaching MACE.
Synapse prepared expert testimony on behalf of Sierra Club on the Georgia Power Company 2016 Integrated Resource Plan and Demand-Side Management Plan. The testimony built off of participation in a multi-stakeholder working group over several months. The testimony critiqued the planning process used to develop the DSM Plan, critiqued the cost-effectiveness analysis used to develop the DSM Plan, recommended an expanded set of DSM programs, and recommended that Georgia Power Company conduct a comprehensive rate and bill impact analysis to assess the equity issues raised by the DSM programs.
Synapse has been retained to evaluate National Grid’s Massachusetts rate design proposals, filed as part of its 2016 rate case. In its application, the Company proposed to impose tiered customer charges on residential and small commercial customers intended to act as a proxy for a demand charge. Synapse submitted testimony that demonstrated why the Company’s proposal not only failed to improve customer equity, but would also be unnecessarily complex, difficult for customers to respond to, and would undermine price signals for energy efficiency and distributed energy resources. Specifically, Synapse conducted statistical analysis to show that the Company’s proposed proxy for a demand charge was no better of an indicator of customer demand than an energy charge, and also failed to account for customer demand diversity and the coincidence with system peak demands.
Rebuttal Testimony of Tim Woolf and Melissa Whited Regarding National Grid Rate Design Proposal
New England’s growing dependence on natural gas has had some in the region worrying about supply constraints. In fact, concerns about natural gas supply and the impacts of proposed new pipelines prompted no fewer than three separate studies on the issue last year. In 2015, three consulting firms released separate reports for different clients analyzing the need for incremental natural gas pipeline in New England through 2030. The three distinctly different approaches to the studies have the potential to create uncertainty for those trying to compare the results. To address this confusion, Synapse produced a white paper which reviews the main differences in the methods and inputs for each of the three studies, along with their results and key findings.
Synapse through its subcontractor John Rosenkranz, provided New Jersey Rate Counsel with technical advice to review New Jersey Natural Gas' annual Basic Gas Supply Service (BGSS) and Conservation Incentive Program (CIP) filings.
Synapse reviewed the modeling methodology used by Portland General Electric (PGE) in the development of its 2016 Draft Integrated Resource Plan. Synapse found that PGE’s methodology lacked rigor and, as such, did not sufficiently justify its portfolio selection for the draft IRP. In comments submitted on behalf of Sierra Club during a stakeholder feedback process, Synapse recommended that PGE address the flaws in the selection process by (1) conducting optimization modeling, (2) performing a probabilistic analysis, (3) replacing its unreliable metrics with standard measures, (4) providing scenario results to stakeholders, and (5) involving stakeholders in future procurement decisions.
Comments to Oregon PUC on PGE 2016 Integrated Resource Plan
On behalf of the New Jersey Division of Rate Counsel, Synapse reviewed and provided comments on the proposed revisions to New Jersey's technical reference manual titled "New Jersey Clean Energy Program Protocols to Measure Resource Savings." Synapse's comments focused on the key data sources; assumptions and savings algorithms for various end uses; and projects such as ground source heat pump, HVAC, hot water, LED lighting, new construction, appliances and electronics.
On behalf of Sierra Club, Synapse reviewed the Tucson Electric Power Company’s (TEP) rate application submitted to the Arizona Corporation Commission. Specifically, Synapse reviewed TEP’s decision to retire the San Juan Generation Station (SJGS) Unit 1 in 2027 and its request to recover costs from ratepayers for a $34 million investment in two pollution control projects at the unit. Synapse found that TEP did not exercise due diligence in supporting its recommendation of a 2027 retirement and its capital expenditures, relying heavily on another owner of the plant, Public Service Company of New Mexico. TEP conducted its own analysis in 2012 and 2013, prior to several major changes that affect the economics of San Juan. Synapse’s analysis found that the unit is unlikely to be economic after 2022. As such, Patrick Luckow submitted expert testimony recommending that the Commission reject the proposed 2027 retirement in favor of a 2022 retirement.
Synapse analyzed least-cost strategies for reducing emissions 40 percent below 1990 levels in Regional Greenhouse Gas Initiative (RGGI) states by 2030. Synapse’s analysis focused on four well-researched, cost-effective emission reduction measures: energy efficiency, wind and solar generation in the electric sector, and conversion from gas-powered to electric light-duty vehicles in the transportation sector. Using a purpose-built version of Synapse's Multi-Sector Emissions Model (MSEM) and the National Renewable Energy Laboratory’s Regional Energy Deployment System (ReEDS) to model emissions in the RGGI states, Synapse analyzed the impacts of adding the following measures to the RGGI states’ existing goals:
- Converting one-third of all light-duty vehicles from gas to electric
- Achieving Massachusetts’ level of energy efficiency savings in all RGGI states
- Investing in onshore wind generation up to the economically achievable potential
- Limited investments in utility-scale solar installations
Version 2.0 of the resulting report considers the gas and oil savings (co-benefits) from electric energy efficiency measures and the electric savings from gas energy efficiency measures. It also includes two new carbon dioxide emission reduction measures that were not considered in our original January 2016 report:
- Gas energy efficiency measures in the residential, commercial, and industrial sectors
- The replacement of aging residential oil heating systems with air-source heat pumps (efficient electric heating units)
In addition, this study:
- revises the methodology for choosing which emission reduction measures to include in the modeling by incorporating the cost of powering electric vehicles with renewables;
- reallocates the installation of onshore wind generators across Northeast states to be more consistent with expected wind speed potential; and
- uses updated levelized costs of energy for onshore wind and utility-scale solar, reflecting the best information available at the time of publishing.
- With these measures in effect, lower emission reductions are required of the electric sector to reach the same 40-percent all-sector emissions reduction target for the nine Regional Greenhouse Gas Initiative states.
Subsequent to this study, Synapse presented a webinar in which Synapse staff used RGGI as a case study to demonstrate the use of Synapse's Multi-Sector Emissions Model (M-SEM). View presentation here.
The RGGI Opportunity 1.0
The thermal energy sector, which relies primarily on fossil fuels, accounts for approximately one third of Rhode Island’s total energy consumption and total carbon emissions. By diversifying the thermal energy sector to increase use of low-carbon renewable heating and cooling technologies (e.g., air source heat pumps, ground source heat pumps, wood pellet heating, solar thermal), Rhode Island can make significant strides toward achieving greenhouse gas emission reduction goals while producing substantial economic benefits for the state. To meet these objectives, the Rhode Island Office of Energy Resources tasked Synapse and Meister Consultants Group with (a) analyzing policies and programs designed to grow the renewable thermal industry and (b) conducting a detailed market model of an alternative thermal sector energy future. This market model analyzed the cost-effectiveness, energy rate and bill impacts, local job impacts, and emission impacts of an alternative future in which Rhode Island achieves five percent renewable energy penetration by 2035.
Kenji Takahashi presented on "Rhode Island Renewable Thermal Market Strategy -- An Analysis of Energy, Environmental, Economic, Energy Bill, and Local Job Impacts of an Alternative Renewable Thermal Energy Future for Rhode Island" at 2017 Energy Efficiency in Domestic Appliances and Lighting Conference.
Synapse reviewed the engineering aspects of Rockland Electric Company’s recent distribution system investments included in the Company’s recent rate case.
Synapse assisted the New Jersey Division of Rate Counsel in evaluating Rockland Electric Company’s (RECO) proposal for investments in advanced metering infrastructure (AMI). The company’s proposal seeks pre-approval to install approximately 73,880 advanced meters across its entire New Jersey service territory. RECO’s petition in a previous docket, which Synapse also evaluated, proposed AMI deployment for only a subset of customers. Tim Woolf submitted initial direct testimony to the New Jersey Board of Public Utilities arguing against pre-approval of AMI investments.
Jurisdictions across the country are grappling with the challenges and opportunities associated with rapidly increasing adoption of distributed solar resources. While distributed solar can provide many benefits – such as increased customer choice, decreased emissions, and decreased utility system costs – in some circumstances it may result in increased bills for non-solar customers. Utility regulators and state policy-makers face the difficult task of striking a balance between ensuring that cost-effective clean energy resources continue to be developed, and avoiding unreasonable rate and bill impacts for non-solar customers.
This report, prepared by Synapse for Consumers Union, provides a framework for helping decision-makers analyze distributed solar policy options comprehensively and concretely. This framework is grounded in addressing the three key questions that regulators should ask regarding any potential distributed solar policy:
- How will the policy affect the development of distributed solar?
- How cost-effective are distributed solar resources?
- To what extent does the policy mitigate or exacerbate any cost shifting to non-solar customers?
Answering these questions will enable decision-makers to determine which policy options best balance the protection of customers with the promotion of cost-effective distributed solar resources.
Show Me the Numbers Slide Deck
The New York Public Service Commission has undertaken an ambitious initiative to improve system efficiency, empower customer choice, and encourage greater penetration of clean generation and efficiency technologies. Called the Reforming the Energy Vision initiative, or REV, this case has proceeded on two tracks. The focus of Track Two is to examine what regulatory changes in current regulatory, tariff, and market designs and incentive structures are needed to better align utility interests with achieving the PSC’s objectives. Synapse provided the Natural Resources Defense Council (NRDC) with analytical and policy expertise to help NRDC ensure that REV Track Two: (1) results in a regulatory and ratemaking model for New York that moves away from electricity as a commodity, (2) promotes the penetration of clean and renewable resources, (3) ultimately decarbonizes the electric sector, and (4) becomes a model for other jurisdictions. Synapse assisted NRDC in this matter by conducting and quantitative research and analysis to inform NRDC comments and proposals, developing and executing work plans for strategic engagement in REV Track Two, working with NRDC to draft submissions to the PSC, and otherwise participate in REV-related stakeholder processes, where required.
Synapse also assisted NRDC with Track One issues.
Comments on New York State Department of Public Service Reforming the Energy Vision Benefit-Cost Analysis White Paper
Reply Comments on New York State Department of Public Service Reforming the Energy Vision Benefit-Cost Analysis White Paper
Comments on New York State Department of Public Service Reforming the Energy Vision Track 2 White Paper
Reply Comments on New York State Department of Public Service Reforming the Energy Vision Track 2 White Paper
Comments on New York State Department of Public Service Distributed System Implementation Plan Guidance
Reply Comments on New York State Department of Public Service Distributed System Implementation Plan Guidance
Comments on New York Public Service Commission Initial Distributed System Implementation Plans
Reply Comments on New York Public Service Commission Initial Distributed System Implementation Plans
Comments on New York Public Service Commission Supplemental Distributed System Implementation Plans
Reply Comments on New York Public Service Commission Supplemental Distributed System Implementation Plans
Comments on VDER Phase 1 Implementation Plans
Synapse provided technical and policy support for several aspects related to the NY REV Initiative. This included drafting detailed comments and reply comments on the New York Utilities' proposed Distribution System Implementation Plans, with an emphasis on ensuring that distributed energy resources are properly planned for and implemented. It also included a detailed review of NY energy efficiency activities and recommendations for how to promote the implementation of all cost-effective energy efficiency resources as part of the NY REV initiatives. This work also included technical support for estimates of avoided distribution costs at constrained locations on the grid; i.e., the "value of D."
You can find the Synapse report Gas Regulation for a Decarbonized New York, part of our support for NY REV, here.
Direct Testimony of Tim Woolf on CHGE Proposed EE EAM
The National Standard Practice Manual and the Value of Energy Efficiency in New York
A decade ago, the purpose of integrated resource plans (IRPs) was clear: find a least-cost way for central utilities to meet expanding energy needs. Today, a dramatically new energy landscape is shifting the purpose of IRPs. On June 16, 2016, Synapse's Principal Associate Dr. Jeremy Fisher, Senior Associate Dr. Ariel Horowitz, and Senior Associate Patrick Luckow reviewed the changing functions of IRPs across the United States during a Synapse webinar. They explored how the latest IRPs evaluate the costs and benefits of existing resources, assess the impacts of environmental regulations, integrate renewable energy, and address higher penetrations of distributed generation.
A study of the relative costs of operating each of the four Dallman Units.
Synapse assisted Sierra Club and its fellow coalition members in their involvement in a Utah net metering proceeding (Utah Division of Public Utilities Docket No. 14-035-114). Synapse provided support for four technical conferences: on technical valuation, economic valuation, cost-effectiveness valuation, and rate design and cost of service.
On behalf of the Southern Environmental Law Center, Synapse provided analysis and testimony for two dockets in front of the South Carolina Public Service Commission. In dockets 2016-1-E and 2016-3-E (ongoing), petitioners Duke Energy Progress and Duke Energy Carolinas proposed updated value of solar calculations in their respective annual fuel cost dockets. These updates track compliance with the 2014 settlement regarding distributed energy resources such as residential PV. Witness Thomas Vitolo, PhD, submitted written testimony regarding the appropriate calculation of benefit categories associated with the value of solar calculation.
Surrebuttal Testimony of Thomas Vitolo PhD Regarding Duke Energy Carolinas NEM Methodology
On behalf of the Southern Environmental Law Center, Synapse provided analysis and testimony in front of the South Carolina Public Service Commission. In docket 2016-2-E, petitioner South Carolina Electric & Gas proposed updated value of solar calculations in its annual fuel cost docket. These updates track compliance with the 2014 settlement regarding distributed energy resources such as residential PV. Witness Thomas Vitolo, PhD, submitted written testimony regarding the appropriate calculation of benefit categories associated with the value of solar calculation. Project completed July 2016.
On behalf of the Southern Environmental Law Center and Appalachian Mountain Advocates, Synapse analyzed the need for additional natural gas pipeline infrastructure in Virginia. No fewer than three new gas pipelines are proposed to run through West Virginia and Virginia: 1) the Atlantic Coast Pipeline, a 550-mile pipeline proposed by Dominion, Duke Energy, Piedmont Natural Gas, and AGL Resources; 2) the Mountain Valley Pipeline, a 330-milepipeline proposed by EQT Corporation and NextEra; and 3) the Appalachian Connector Pipeline (formerly called the Western Marcellus Pipeline), an expansion of the Transco interstate pipeline proposed by Williams. All three projects will require approval from the Federal Energy Regulatory Commission (FERC), which considers such projects on a case-by-case basis. Synapse staff led a project to assess the region’s pipeline needs system-wide to determine capacity needs and to compare these needs to expected future demand for natural gas.
The American Wind Energy Association (AWEA) retained Synapse to provide an analysis of potential future wind policies. Synapse modeled a suite of policy sensitivities using NREL’s ReEDS model, including a business-as-usual case, carbon tax case, and variations on the form of production tax incentives. For all cases, modeling included all U.S. states over the time period 2016-2030.
One of the key benefits most attributed to energy efficiency and renewable energy (clean energy resources) is that they reduce the use of fossil fuel resources consumed for generating electricity, and in doing so reduce fossil fuel-related carbon dioxide emissions. Synapse reviewed a range of sources and compiled evidence that clean energy resources have indeed displaced generation by fossil resources connected to the grid, and that they are projected to continue doing so in the future. The report includes:
- utility-level case studies of electric system integrated resource planning (IRP) model results;
- a review of national-level analyses;
- an overview of marginal resources in different regional transmission organization (RTO) areas;
- modeling case studies using EPA’s AVERT; and
- a review of historical data demonstrating the impact that energy efficiency and renewable energy have already had on fossil fuel use.
In addition, the report highlights original Synapse analysis using the ReEDS model on the impacts of expanding clean energy resources on emissions related to fossil-fuel generation.
In 2014, Ameren Missouri submitted its proposed 2016-2018 Energy Efficiency Plan under the Missouri Energy Efficiency Investment Act (MEEIA). The Act stipulates that utilities should implement demand-side programs with the goal of achieving all cost-effective demand-side savings. On behalf of Sierra Club, Synapse reviewed the proposed three-year plan and submitted expert testimony with recommendations for how the plan could be improved to increase the benefits available to Ameren customers and to the Company.
Surrebuttal Testimony of Tim Woolf Regarding Ameren Missouri 2016-2018 Energy Efficiency Plan
Synapse analyzed the residential demand response programs of three New Jersey electric distribution companies.
The Massachusetts Department of Energy Resources (DOER) commissioned a study to analyze how a possible revenue-neutral carbon tax (or fee) could be implemented in the Commonwealth. To explore the implications of a state-specific carbon tax, Synapse and Regional Economic Models, Inc. (REMI) developed a methodology for incorporating the supply-side energy system effects of CO2 pricing in the REMI macroeconomic models of the United States. Synapse used the ReEDS model to explore emissions and cost impacts of several policy structures for Massachusetts as well as for the rest of New England and the rest of the RGGI states.
Since 2005, Synapse has provided analysis of New Jersey's Basic Generation Service (BGS) procurement options for the New Jersey Division of Rate Counsel. The BGS procurement process includes annual auctions held by the State of New Jersey for the procurement of fixed-price, basic electric generation service (BGS-FP). BGS-FP service is the name of the rate plan for those residential and small commercial customers who choose not to use a competitive supplier for their electricity needs. Synapse's BGS procurement analysis takes into consideration the BGS auction process and other factors relevant to procurement options for NJ BGS customers. Synapse's analyses include assessment of procurement options in other states; futures markets for electricity, natural gas, and coal; recent auction/RFP results for BGS-FP-equivalent services from other states; PJM technical issues affecting BGS procurement considerations; and other relevant issues. Project work for the 2012 proceeding completed in April 2013.
Synapse is providing expert technical consulting services to the District of Columbia’s Office of the Attorney General related to Exelon Corporation’s proposed acquisition of Pepco Holdings. Specifically, Synapse reviewed the Joint Applicants' economic impact analysis; merger-related reliability issues; risks associated with the Joint Applicants’ affiliated non-jurisdictional business operations and issues related to conservation of natural resources and preservation of environmental quality. Synapse is submitting testimony in the legal proceeding on behalf of the District of Columbia Government. Synapse performed similar analysis related to the merger on behalf of clients in Delaware, Maryland, and New Jersey.
Direct Testimony of Max Chang on Reliability, Risk, and Environmental Impacts of Exelon-Pepco Merger
Answering Testimony of Tyler Comings on the Economic Impact Analysis of the Exelon-PHI Merger
Answering Testimony of Max Chang on Reliability Impacts of the Exelon-PHI Merger
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