Synapse Energy Economics joined with Sustainable Energy Advantage (SEA), as well as members from NECEC, Mass Energy Consumers Alliance, E4theFuture, and other organizations to analyze the current state of regional renewable portfolio standards in light of many of new policy actions that have been put into place over the last several years. These policy actions include new legislation requiring long-term contracting for renewables and other resources in Massachusetts, Connecticut, and Rhode Island, revised incentives for distributed generation resources, changes to RPS polices in other states in New England, proposed Massachusetts-specific CO2 caps, and newly-revised forecasts for electricity sales that take the full impact of new energy efficiency measures into account.
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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. Based on its analysis of the 2017 proposal, Synapse recommended that the BGS process should not move away from procuring a fixed price product that was meant to protect ratepayers form market volatility to a product that slowly increases protection for bidders at ratepayers’ expense.
On behalf of Consumers for Sensible Energy and a number of other non-governmental organizations, Synapse analyzed the need for, and the cost of, the Access Northeast (ANE) natural gas pipeline. As proposed, the ANE pipeline relies on a new funding mechanism whereby electric ratepayers would pay for new gas pipelines. This unprecedented funding proposal has spurred controversy and litigation: the Massachusetts Supreme Judicial Court and the New Hampshire Public Utilities Commission both rejected this approach, declaring that it violates state laws enacted to restructure the electric utility sector and to protect consumers from undue financial risk. Pipeline proponents claim that the ANE pipeline is needed to relieve capacity constraints on New England’s natural gas pipeline system and that the cost of the pipeline is justified because it will ultimately save money for New England electric ratepayers.
Synapse’s analysis showed otherwise. Any savings created by the ANE pipeline are likely to be outweighed by its costs, which are more than twice what proponents have generally reported. The analysis also indicated that the need for natural gas in New England will decrease dramatically within a few years of ANE’s construction. This would alleviate the capacity constraints cited to justify the pipeline. Synapse modeled energy use, prices, and emissions in a base scenario in which there is no new pipeline compared to a scenario in which the ANE pipeline is constructed.
New England's Shrinking Need for Natural Gas
Synapse’s Rachel Wilson provided analysis and testimony on an Avista Corporation rate case before the Washington Utilities & Transportation Commission. Ms. Wilson evaluated Avista’s production cost modeling, which used the AuroraXMP model, to determine if its requested increase in power costs was reasonable. She found that Avista’s modeling methodology led to a sustained overestimate of annual power supply costs, as evidenced by the compounding of credit deferral balances in its Energy Recovery Mechanism. Ms. Wilson recommended that Avista recalibrate its modeling to allow the Energy Recovery Mechanism to function as intended—to capture the variability between modeled and actual power supply costs. She further recommended that Avista more fully explore the possibility of joining the Western Energy Imbalance Market, which is a real-time wholesale energy market in which participants can buy and sell energy when needed.
Synapse developed a comprehensive framework for balancing the growth of distributed solar with customer protection. Rooted in fundamental ratemaking and long-term resource planning principles, this framework enables regulators, consumer advocates, and other stakeholders to assess the merits of distributed solar against its potential for inequitable cost-shifting from solar customers to non-solar customers. The framework is grounded in addressing the three key questions that regulators should ask regarding any potential distributed solar policy: (1) How will the policy affect the development of distributed solar? (2) How cost‐effective are distributed solar resources? and (3) 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. This report describes the analyses that can be used to answer these questions.
The Southwest Energy Efficiency Project (SWEEP) conducted a study on benefits of residential heat pumps for space heating and water heating in five major cities in the Southwest. Kenji Takahashi of Synapse Energy Economics played a key advisory role assisting SWEEP with conducting the first major analysis of heat pumps against natural gas heating in the region. More specifically, he reviewed, advised, and offered recommendations on key assumptions and methodologies for evaluating energy, economic, and emissions impacts of heat pumps.
You can read the report on SWEEP's website.
In 2014-2015, Berkshire Gas in Massachusetts placed a moratorium on new services in part of its territory after identifying distribution capacity constraints and insufficient supply resources. On July 8, 2016, Berkshire Gas filed a petition with the Department of Public Utilities seeking approval of its Long-Range Forecast and Supply Plan (F&SL) under D.P.U. 16-103. The company based its plan on analysis of various resource options to increase access to natural gas for the region as a precursor to lifting the moratorium.
On behalf of the Town of Montague, Synapse reviewed and assessed the reasonableness of Berkshire Gas’s F&SL. Our review of the resource plan revealed that while the plan included energy efficiency and demand response as options, it gave little attention to such resources. Instead, the company recommended investment in extensive and expensive new infrastructure options. We concluded that the company could lift the moratorium by implementing a few simple steps: (a) re-establish curtailable agreements with two large customers that already have dual-fuel capability, and (b) change the way it estimates impacts from current and future energy efficiency programs. We also identified additional demand-side resource potential by analyzing the historical performance of gas energy efficiency programs in New England, current program offerings, and a new gas demand-response program based on internet-connected thermostats. Our analysis concluded that with these expanded demand-side resources, the company could expect future peak load to decline from today’s level over the next five years. Furthermore, the future load forecast could be even lower if it incorporated potential impacts from emerging technologies and other factors. Specifically, electric heat pumps and the state’s existing climate change policies are highly likely to lead to substantial electrification in various sectors and to lower overall gas consumption.
Using Demand-Side Resources to End a Moratorium on New Customers for a Local Natural Gas Company in Massachusetts
Synapse prepared a summary of best practices in utility demand response (DR) programs and then compared those practices with HydroQuebec Distribution's planned DR resource and programs in their 2017-2026 Supply Plan, resulting in a set of recommendations for programmatic activities and revised planning processes. Synapse produced an expert report as well as a presentation used during live testimony.
Best Practices in Utility Demand Response Programs (Testimony Slide Deck)
In February 2017, the utilities with ownership of Navajo Generating Station in Arizona voted to cease operations of the coal-fired power plant. Two months later, Peabody Energy, operator of the mine that supplies fuel to Navajo, presented an analysis before the Arizona Corporation Commission demonstrating that Navajo is economically viable. On behalf of Sierra Club, Synapse examined this study, which was commissioned by Peabody and conducted by Navigant. Synapse found that Navigant relied on overstated market energy prices and understated Navajo's fuel prices, resulting in nearly $2 billion in errors.
The Los Angeles City Council has mandated that the Los Angeles Department of Water and Power (LADWP), the largest municipally-run utility in the United States, analyze powering 100 percent of demand with renewable energy. To date, LADWP's efforts have been insufficient, as the utility has only published an analysis of a slight increase over current renewable energy targets and is not planning to finalize their 100 percent renewable study until 2020 at the earliest.
Food & Water Watch engaged Synapse to analyze a potential pathway to 100 percent clean energy in Los Angeles by 2030. In our study, we found that it is possible for LADWP to exclusively use renewable resources to power its system in every hour of the year. What's more, we found that under one of the clean energy pathways analyzed, the transition to 100 percent renewable energy in every hour of the year can occur at no net cost to the system. The resulting report, Clean Energy for Los Angeles, provides a roadmap for how to achieve 100 percent renewables by integrating and harnessing renewable energy more efficiently and investing in additional efficiency, storage, and demand response.
Although the report only focuses on a single city, the results are important and applicable to many other parts of the country. Los Angeles's 4 million residents make the city larger than 22 entire states, while the annual energy served by LADWP is greater than sales in 13 individual states, indicating that if this transition is possible in Los Angeles, it is feasible in other parts of the country as well.
Synapse was engaged by Riverkeeper and the Natural Resources Defense Council (NRDC) to analyze replacement energy and capacity resources associated with the retirement of the Indian Point Energy Center (IPEC). Synapse utilized the National Renewable Energy Laboratory ReEDS modeling system to estimate an economically optimal expansion of renewable energy resources in New York that would (i) meet Clean Energy Standard (CES) requirements; (ii) achieve required energy and capacity requirements with IPEC retired so as to maintain reliability, and (iii) track the energy production and capacity expansion costs of meeting all New York State requirements during the period 2016 to 2030. Our analysis found that the most cost‐effective replacement resource scenario includes an increase in the level of energy efficiency procurement in New York State above and beyond assumed CES levels, towards the most aggressive, achievable energy efficiency levels that NYSERDA and New York utilities can achieve. Increased levels of energy efficiency investment—and clear direction from the Public Service Commission to ensure those levels in fact materialize—will reduce the cost of achieving the CES’s 50 percent by 2030 renewable energy requirement.
Synapse evaluated an "Empower Kentucky" plan on behalf of Kentuckians for the Commonwealth. Synapse worked closely with stakeholders in Kentucky to develop inputs to be used in modeling, then used NREL's Renewable Energy Deployment System (ReEDS) and IMPLAN, to evaluate a business-as-usual future and an Empower Kentucky future in which Kentucky embraces energy efficiency, renewables, and a carbon price. Through this analysis, Synapse found that an Empower Kentucky future would produce significant benefits in emission reductions, residential bill reductions, and increases in jobs for Kentuckians.
On behalf of the Illinois Office of the Attorney General, Synapse reviewed Commonwealth Edison Company’s (ComEd) proposal for a voltage optimization validation project within the context of ComEd’s formula rate proceeding. Principal Associates Max Chang and Bob Fagan submitted testimony before the Illinois Commerce Commission (Case 16-0259) addressing ComEd’s planned Voltage Optimization Validation Program and its opportunities for data analytics. Synapse’s analysis found that ComEd’s validation study did not adequately demonstrate that the program would address the company’s challenges. Mr. Chang and Mr. Fagan recommended that the Commission direct ComEd to adopt a more comprehensive and robust validation study for voltage optimization. Mr. Chang and Mr. Fagan also recommended that the Commission require ComEd to provide information regarding the development of a long-term plan to fully utilize data gathered from the installation of smart meters and modern distribution infrastructure.
Synapse analyzed the impacts of increasing the Connecticut Renewable Portfolio Standard.
In 2016, Synapse provided a report estimating the net savings for a typical car and light truck owner associated with compliance with proposed federal fuel economy standards for 2025. In March 2017, Synapse conducted additional analyses addressing automaker claims that the fuel economy standards hurt households and affordability of new vehicles. We found that actual fuel economy improvement in the last ten years has saved households’ bottom line.
More Mileage for Your Money
Sierra Club retained Synapse to review Dayton Power and Light’s (DP&L) application for approval of an electric security plan (Cases No. 16-0395-EL-SSO, 16-396-EL-ATA, and 16-397-EL-AAM). Synapse’s review focused on DP&L’s proposed Distribution Modernization Rider (DRM) and the value and outlook of the Company’s coal fleet. The proposed DRM would charge ratepayers $145 million per year over seven years. These charges would subsidize risky capital investments in the Company’s coal assets—several of which have been determined by other owners to have value and be unreliable. On behalf of Sierra Club, Tyler Comings submitted testimony to the Public Utilities Commission of Ohio demonstrating the coal fleet’s low value and poor reliability and recommending that the Commission deny the DMR.
Synapse launched a report in the fall of 2018 examining the technology options and impacts for building decarbonization in California, with a primary focus on air source heat pumps for space and water heating. The report examines electric grid impacts as well as the impact on customer economics. This included a detailed comparison of customer economics under different existing and near future rate structures. The report concludes with a set of recommended actions, including policy changes, to accelerate market transformation in the building sector.
Synapse reviewed assumptions in Delmarva Power and Light’s benefit-to-cost analysis of its Advanced Metering Infrastructure (AMI) Initiative. Max Chang submitted testimony on behalf of Maryland OPC demonstrating that, due to unreasonable assumptions, DPL overestimated the benefit to cost ratio of the AMI program for the 2015-2024 period. Mr. Chang recommended that the Commission disallow $34 million in order to protect ratepayers.
On behalf of the Office of the People's Counsel for the District of Columbia (OPC), Synapse evaluated several aspects of distributed generation in Washington, DC. This project consisted of three research topics. First, Synapse researched and offered recommendations regarding policies that can sustainably support the development of distributed generation in the District, while avoiding adverse consequences. Second, Synapse assessed the technical and economic potential for distributed generation in the District, particularly solar photovoltaics (PV). Finally, Synapse conducted a benefit-cost analysis of solar in the District.
OPC Reply Comments Regarding Pepco Comments on Value of Solar Study
Synapse was retained by Earthjustice to draft a whitepaper discussing grid resiliency issues in the context of the United States Department of Energy (DOE)’s “grid resiliency pricing rule” proposal. DOE’s proposal directed the Federal Energy Regulatory Commission (FERC) to design rules that would guarantee full recovery of costs for all generating units operating in competitive wholesale markets with 90 days of fuel supply on-site (conventionally understood to refer to nuclear and coal-fired units). Synapse’s whitepaper discusses several key problems associated with this proposal: first, the authorities in charge of the nation’s wholesale energy markets (including FERC itself as well as ISO/RTOs and state agencies) have devoted substantial efforts to increasing the reliability and resiliency of the grid system and have reasonable, market-based approaches for accomplishing this goal. Second, fuel supply disruptions have not historically been a significant cause of service interruptions. Third, coal units in particular are vulnerable to both fuel supply disruptions and other failures during extreme weather and temperature events, and have demonstrated decreasing reliability over time. Synapse’s whitepaper was filed under FERC docket RM18-1-000 in support of comments submitted by Earthjustice, Environmental Defense Fund (EDF), Natural Resources Defense Council (NRDC), Sierra Club, Sustainable FERC Project, the Union of Concerned Scientists (UCS), the Center for Biological Diversity, the Environmental Law and Policy Center, the Southern Environmental Law Center (SELC), Conservation Law Foundation (CLF), Environmental Working Group, and Fresh Energy.
The Dakota Access pipeline, proposed in 2014, was designed to carry crude oil from the Bakken oil field in western North Dakota, through South Dakota and Iowa, to a pipeline hub in southern Illinois. The final stages of construction, not yet completed, have become the subject of a wide-ranging controversy involving multiple environmental, legal, cultural, and economic issues.
In February 2017 Synapse produced a report based on research performed for Fredericks Peebles & Morgan LLP, attorneys for the Cheyenne River Sioux, addressing one dimension of the controversy: the economic impacts of completing the Dakota Access pipeline.
As a continuation of previous work, Synapse provided NS UARB with consulting services on energy efficiency issues. Specifically, Synapse provided technical support and analysis with respect to rate and bill impacts, low-income program participation and performance, methodology to determine program incentives, and benefits of location-specific efficiency targeting.
Reply Comments on CLEAResult EfficiencyOne Incentive Setting Methodology
Comments on Revised CLEAResult EfficiencyOne Incentive Setting Methodology
Comments on EfficiencyOne 2016 Rate and Bill Impact Analysis
Comments on Efficiency Nova Scotia 2017 DSM Progress Report
The Maryland Office of People’s Counsel retained Synapse to review the independent assessment of two offshore wind applications before the Maryland Public Service Commission in Case 9431. The two proposals under consideration are from US Wind for a 248 MW wind farm and Deepwater Wind for a 120 MW wind farm. Maryland's Offshore Renewable Energy Credit legislation establishes administrative thresholds for each offshore wind application and evaluation criteria for the Commission to use in its review. Synapse reviewed the findings, inputs, and calculations of the independent assessment and the two applications to provide recommendations regarding the renewable energy credit payments, ratepayer impacts, economic impacts, and net benefits attributed to each proposed project. Max Chang submitted testimony on behalf of MD OPC in March 2017.
Massachusetts’ Green Communities program helps the state’s 351 cities and towns find and successfully implement clean energy solutions. To receive Green Community designation, communities must develop and implement a plan to reduce energy use by 20 percent within five years and meet additional criteria including allowing for permitting and siting of renewable energy, purchasing fuel-efficient and alternative fuel vehicles, and adopting more stringent building codes. The Massachusetts Department of Energy Resources engaged Synapse to review Green Community Annual Reports, verify whether municipalities have reached their 20 percent energy reduction goal, and develop a Progress Report for the program highlighting achievements to date. Synapse also identified strategies that are effective across towns and made recommendations to continue to advance and improve the program. Synapse developed the Green Communities Program 2016 Progress Report, available here, and provided updated analysis for 2017 and 2018.
Synapse reviewed the analysis conducted by Idaho Power Company (IPC) in support of its 2017 Integrated Resource Plan. In comments submitted on behalf of Sierra Club, Synapse identified concerns including a lack of rigorous modeling, the selection of an illegal resource plan, under-statement of future coal unit costs, and the lack of rigorous evaluation of the economic status of existing IPC coal units. Synapse recommended that IPC conduct optimization modeling in future IRPs, and fully assess the status of its Jim Bridger coal plant with respect to reasonable alternatives.
Sierra Club Final Comments on Idaho Power Company's 2017 IRP
Synapse is assisting the Hawaii Division of Consumer Advocacy in an investigation to reexamine the existing decoupling mechanisms for the Hawaiian Electric Companies (Docket 2013-0141). The Hawaii Public Utilities Commission opened this investigation to determine whether the existing decoupling mechanisms, including both the Revenue Balancing Account (RBA) and the Revenue Adjustment Mechanism (RAM), are effectively serving their intended purposes, are fair to the HECO Companies and ratepayers, and are in the public interest. Schedule A of this docket addressed interest rates, tax deferrals, risk sharing mechanisms, baseline projects in RAM, and performance metrics. Schedule B of this docket will address issues concerning the RAM, particularly related to the incentives that the RAM provides or fails to provide, the fair allocation of risk, and ways to increase the efficiency of ratemaking. Synapse is taking a lead role in reviewing and commenting on the development of HECO’s performance metrics associated with Schedule A, and is leading the development of the Consumer Advocate’s statements of position regarding performance incentives in Schedule B, including analysis of how such incentives might interact with the decoupling mechanism.
On behalf of Not Another Power Plant and Sierra Club, Synapse’s Bob Fagan submitted Direct and Surrebuttal expert testimony to the Connecticut Siting Council regarding the Killingly Energy Center, a 550 MW combined cycle power plant proposed for Killingly, Connecticut. He testified at two separate Siting Council hearings concerning the proposed plant. Mr. Fagan’s testimony clearly demonstrated that there are no short-term or longer-term reliability needs for the proposed plant. Further, increased renewable resources and energy efficiency required to meet increasing greenhouse gas emission limits will provide more than sufficient energy and capacity to meet reliability needs.
Surrebuttal Testimony of Bob Fagan Regarding Proposed Killingly Energy Center
Maine’s low-income residents, like those throughout the United States, face higher energy burdens (i.e., spend proportionally more of their budgets on electricity and heating fuels) than other residents. While Maine has addressed this disparity through various measures for decades, the state and other relevant entities can act more effectively by gaining a better understanding of how and where this disparity tends to strike. With this in mind, the Maine Office of the Public Advocate commissioned a study by Synapse Energy Economics (Synapse) to shed light on the energy burdens faced by Maine’s residents. The resulting report describes Synapse’s findings on energy use in homes. We relied on various publicly available federal data sources such as the U.S. Department of Energy’s Low-Income Energy Affordability Data (LEAD) tool. We assessed differences in home energy expenditures by income bracket, by home ownership status, by type of heating fuel, and by county. The analysis reveals that Maine’s low-income households have a high energy burden: The average (mean) home energy burden for low-income households is 19 percent. On average, low-income households in the state far exceed the thresholds for the various definitions of energy poverty (generally starting with a minimum energy burden in the range of 6 to 10 percent of household income). In comparison, we find in our analysis that the average home energy burden for all Maine households is 6 percent.
Madison G&E is seeking to build 66 MW of wind in Iowa in Docket 3270-CE-127. Synapse provided expert testimony on behalf of Sierra Club regarding the Company's assumptions and modeling. Key questions included whether or not larger turbines or simply a larger project would have been more economic.
Synapse reviewed the Maritime Link Interim Cost Assessment. Specifically, Synapse analyzed the value of the Maritime Link asset to ratepayers given costs associated with a delay in delivery of energy via the Maritime Link. Further, Synapse assessed if the Maritime Link Project, approved by NS UARB in 2013, would be “used and useful.” Bob Fagan and Tyler Comings submitted joint direct testimony on these issues to the NS UARB.
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