Indiana Michigan Company (I&M) submitted an application to the Indiana Utility Regulatory Commission seeking a certificate of public convenience and necessity to install Selective Catalytic Reduction at Rockport Power Plant Unit 2 near Rockport, Indiana. Synapse assessed the analysis conducted by American Electric Power Generating Services on behalf of I&M in support of the application. Specifically, Synapse examined if the installation of the controls would be in the interest of I&M’s ratepayers and if the proposal was consistent with regulatory requirements. On behalf of Citizens Action Coalition of Indiana, Sierra Club, and Valley Watch, Dr. Jeremy Fisher submitted testimony to the Commission recommending that the Commission deny the CPCN on the basis that the Company’s analysis is outdated and Rockport 2 is not a reasonable long-term resource.
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Sierra Club retained Synapse to conduct an economic analysis of the J.K. Spruce coal plant, located near San Antonio, Texas. Synapse evaluated the recent economic performance of the plant, the likely performance of the plant over the next two decades, and the availability of cost-effective renewable alternatives to Spruce. Synapse found that the Spruce plant has likely lost more than $100 million relative to the market since 2015, is likely to lose another $100 million from 2017 to 2019, and will only become profitable over the long term if a series of favorable conditions hold. Synapse concluded that Spruce Unit 1 would be unlikely to recover the costs of a proposed new selective catalytic reduction (SCR) pollution control system, and that replacing Spruce with renewables would reduce emissions more comprehensively and cost-effectively than retrofitting Spruce with SCR.
On behalf of the Office of the People's Counsel, Synapse reviewed and assisted with comments regarding the proposed amendments to Chapter 40 District of Columbia Small Generator Interconnection Rules. Our review was informed by industry best practices and focused on whether the proposed modifications would streamline the interconnection process while maintaining the integrity of the distribution system.
2017 annual update of South Carolina Electric & Gas' (SCE&G) avoided costs, to be used in both PURPA QF rates and for Act 236 compliance. Witness Thomas Vitolo, PhD, submitted testimony (Docket No. 2017-2-E).
On behalf of the Northeast Energy Efficiency Partnerships, Synapse and Meister Consultants Group identified the opportunity, costs, and benefits available if strategic electrification is adopted as a key strategy for decarbonization in New York and New England. Dr. Hopkins, Kenji Takahashi, and Pat Knight are primary authors of the resulting report, Northeastern Regional Assessment of Strategic Electrification (July 2017), which characterizes the current markets for efficiency electrification technologies (such as heat pumps and electric vehicles), identifies policies to overcome market barriers, assesses the state of electrification technologies, and models the extent of electrification both possible given market dynamics and required to meet regional greenhouse gas emission goals.
Southwestern Electric Power Company (SWEPCO) filed a rate case with the Public Utilities Commission of Texas seeking rate recovery of emission control investments at its Dolet Hills, Flint Creek, Pirkey, and Welsh coal plants. SWEPCO also requested approval of changes to its rate design for net metering customers. Synapse assisted Sierra Club by conducting an economic analysis of (1) the modeling SWEPCO used to justify its emission control investments and (2) the rate and bill impacts of its proposed rate design change. Rachel Wilson filed testimony on behalf of Sierra Club addressing SWEPCO’s economic justification for the retrofits. Melissa Whited filed rebuttal testimony regarding SWEPCO’s proposed Distributed Renewable Generation tariff.
Cross-Rebuttal Testimony of Rachel Wilson Regarding SWEPCO Rate Recovery Application
Cross-Rebuttal Testimony of Melissa Whited Regarding SWEPCO Rate Recovery Application
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 study of the relative costs of operating each of the four Dallman Units.
Sierra Club retained Synapse to review the input assumptions and modeling methodologies underlying the 2017 Integrated Resource Plans (IRP) filed by Arizona Public Service Company (APS) and Tucson Electric Power Company (TEP). In comments submitted on behalf of Sierra Club, Synapse presented evidence that APS's plan to build thousands of megawatts of new natural gas-fired capacity was based on a a series of analytical errors and flawed assumptions including an unrealistically high load forecast, under-statement of available cost-effective energy efficiency, inflated renewable costs, and deflated natural gas prices. Synapse recommended that APS hold off on procuring new gas capacity until it had produced an analysis containing a more reasonable set of assumptions. In comments on TEP's IRP, Synapse recommended that TEP revise its modeling to capture a wider range of scenarios and potential portfolios, and more rigorously assess the economic status of its coal units. Citing Synapse's comments, the Arizona Corporation Commission declined to acknowledge the IRPs submitted by APS and TEP, and imposed a series of requirements to ensure that future IRPs incorporate reasonable load-growth scenarios and evaluate a reasonable range of portfolios and sensitivities.
Initial comments on TEP 2017 IRP
Sierra Club Reply to Staff's Comments and Proposed Order
Southern Alliance for Clean Energy engaged Synapse to provide technical support regarding the Tennessee Valley Authority’s electricity rates. Synapse reviewed trends in electricity prices for industrial and residential customers to assess whether TVA allocates costs across customer classes fairly. Synapse published a white paper on our findings, "Electricity Prices in the Tennessee Valley: Are customers being treated fairly?"
Dr. Asa Hopkins provided testimony before the District of Columbia PSC on behalf of the DC Department of Energy and Environment. Altagas proposed to acquire the District’s gas distribution utility, and Dr. Hopkins testified regarding the suitability of Altagas as a purchaser in light of DC’s goals for greenhouse gas emissions reductions. His testimony included an analysis of the long-term potential for natural gas consumption in the District in the context of an 80 percent GHG emissions reduction across all sectors, and concluded that dramatic reductions in fossil fuel gas consumption are going to be necessary, that renewable natural gas supplies are unlikely to make up the difference, and that WGL would need to change aspects of its business model as the city moves toward its goals. Dr. Hopkins testified regarding the suitability of Altagas’s merger commitments to the District’s GHG goals in light of these conclusions.
Direct Testimony and Exhibits of Dr. Asa Hopkins Regarding Formal Case No. 1142
The DC Circuit Court of Appeals brought the Clean Power Plan back into the spotlight in May 2016, making the unusual move to hear the pending case in front of the entire nine-judge circuit. Synapse has highlighted the potential benefits of implementing the Clean Power Plan since its release last summer. During a webinar on May 26, 2016m Synapse Senior Associate Sarah Jackson and Kate Konschnik of Harvard Law School’s Environmental Policy Initiative discussed the outlook for the Clean Power Plan, including why planning continues for a low-carbon future and what some states and utilities have been up to since the Clean Power Plan was put on hold by the Supreme Court earlier this year.
Jenn Kallay presented a Synapse paper entitled Opportunities to Ramp up Low-Income Energy Efficiency to Meet Climate Plan Goals at the 2016 ACEEE Summer Study on Energy Efficiency in Buildings conference. She discussed key findings and opportunities from the compilation of a dataset on low-income energy efficiency efforts in the United States.
Opportunities to Ramp Up Low-Income Energy Efficiency to Meet Climate Policy Goals (slide deck)
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. Synapse’s analysis of the 2016 BGS Auction examined the price divergence observed between the PSE&G service territory and the other electric distribution companies. Synapse found that higher prices for the PSE&G territory are related to significantly high transmission charges compared to other New Jersey Electric Distribution Company utilities.
Synapse analyzed various options for an enhanced Renewable Portfolio Standard for Maryland, on behalf of the Maryland Climate Coalition. Using a Synapse-adapted version of the National Renewable Energy Laboratory’s Regional Energy Deployment System (ReEDS), we modeled three alternative options through the year 2030 to determine how Maryland could meet an expanded policy cost-effectively. The modeling found that the economic conditions surrounding wind and solar installations would allow the state to meet an expanded RPS in all scenarios analyzed. In addition, analysis showed that the emitting renewable resources currently included in the RPS—such as combustion of industrial by-products—had little impact on meeting RPS policies and were also only minimally affected by the policies themselves.
Enhancing Marylands RPS - Factsheet
Conservation Law Foundation retained Synapse to provide technical analysis related to the petition of Exelon for approval to construct and operate a 200 megawatt combustion turbine electric power generation facility in Medway, Massachusetts. Specifically, Synapse reviewed the modeling and testimony of Analysis Group regarding the proposed facility’s impact on compliance with the Massachusetts Global Warming Solutions Act.
Synapse provided expert technical consulting services to the New Jersey Division of Rate Counsel related to the Southern Company and AGL Resources petition seeking approval of the acquisition of AGL Resources by Southern Company. Synapse filed testimony addressing issues related to competition and market power.
Synapse is actively working with a group of stakeholders to engage in the development of the Energy Information Administration's 2016 Annual Energy Outlook (AEO), to be released in mid-2016. The AEO is a critical source of publicly available information for public interest stakeholders working to improve planning and decision-making in the energy sector. Synapse is participating in working groups associated with three key areas of the 2016 AEO: the renewable energy sector, the electricity sector, and the residential/commercial buildings sector. Modeling of EPA’s Clean Power Plan will be a major change in the 2016 AEO from previous forecasts. Synapse is working with other stakeholders to participate actively in this process and advocate for reasonable policy and technology assumptions.
AEO Buildings Working Group Meeting Notes - February 18, 2016
AEO Electricity Working Group Meeting Notes - February 10, 2016
AEO Renewables Working Group Meeting Notes - February 9, 2016
AEO Buildings Working Group Meeting Notes – December 8, 2015
AEO Electricity Working Group Meeting Notes – December 8, 2015
AEO Renewable Working Group Meeting Notes – December 7, 2015
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.
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 modeled various Clean Power Plan compliance options to determine how big an impact strong energy efficiency policies can have on the achievability and affordability of complying with EPA’s rule. Using the Synapse Clean Power Plan Toolkit, a collection of purpose-built in-house tools and commercial models, including the National Renewable Energy Laboratory’s Regional Energy Deployment System (ReEDS) model, Synapse examined the comparative cost of state implementation plans that maximize available energy efficiency strategies versus a future in which states are not Clean Power Plan‐compliant. Synapse modeled and found savings for each of the 48 continental U.S. states.
The results, updated in the factsheet and accompanying report below, show that if states comply using strategies that encourage cost‐effective energy efficiency, households can save on electricity bills.
Synapse held a series of public webinars on this topic:
- Bill Impacts of the Clean Power Plan Updated -March 17, 2016 View presentation here
- Bill Impacts of the Clean Power Plan - January 14, 2016 | 2 PM EST | View presentation here
- Bill Impacts of the Clean Power Plan (Repeated) - January 19, 2016 | 2 PM EST
Stopping the Clean Power Plan Raises Bills
Cutting Electric Bills with the Clean Power Plan Updated
The Clean Power Plan: Green and Affordable (factsheet)
Cutting Electric Bills with the Clean Power Plan
Cutting Electric Bills with the Clean Power Plan - January 15 Errata
Bill Impacts and the Clean Power Plan (webinar slides)
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 performed analysis of Kentucky’s clean energy options on behalf of Kentuckians for the Commonwealth. In light of the U.S. Environmental Protection Agency’s Clean Power Plan and the related Clean Energy Incentive Program (CEIP), Synapse analyzed Kentucky’s expected generating unit retirements, additions (including renewables), electricity sales growth, and the cost of various energy resources—including energy efficiency. We then conducted a screening analysis using Synapse’s Clean Power Plan Planning Tool (CP3T). The initial results included: Kentucky’s carbon dioxide (CO2) emissions under a reference case, in comparison to rate‐ and mass‐based Clean Power Plan emissions standards; the impact of using more or less energy efficiency to achieve Clean Power Plan compliance; and the extent to which Kentucky is able to take advantage of the CEIP program under alternate scenarios.
The costs of both natural gas and solar power have declined precipitously since the draft Clean Power Plan was released in 2014. EIA’s latest release of the Annual Energy Outlook incorporates many of these new developments along with analysis of the Clean Power Plan. In this webinar from June 9, 2016, Synapse's Senior Associate Patrick Luckow and Senior Associate Pat Knight discuss scenarios in which United States electric sector CO2 emissions could decline by 30 percent by 2030 driven largely by these new realities, combined with economic retirements of older coal plants.
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.
Synapse assisted the Ohio Office of Consumer Counsel with issues related to EPA’s Clean Power Plan. This work included providing consultation and analysis on the plan’s costs to Ohio consumers, allowance trading, energy efficiency as a compliance option, and the impacts of compliance pathways on bills and emissions.
States ramping up their Clean Power Plan compliance planning face a dizzying array of tools available to support their modeling. Synapse Energy Economics and Argonne National Lab examined the modeling choices available to policymakers, energy planners, and stakeholders for the Clean Power Plan and other applications. Together, they produced a report entitled, the Guide to Clean Power Plan Modeling Tools, and an accompanying webinar to delve into the different types of modeling approaches that could be, and are, being used by states and stakeholders to assess compliance plans. In developing these resources, Synapse and ANL considered a number of factors—including EPA reporting requirements, the need for transparency, flexibility, analytic rigor, and geographic specificity—that will be important to successful compliance plans and their implementation. These same considerations are also important for integrated resource planning and other electricity modeling applications.
Guide to Electric Sector Modeling Tools - webinar slides
Synapse hosted a set of webinars and prepared a factsheet on community and environmental justice issues in the Clean Power Plan. EPA requires states to engage vulnerable communities—including low‐income residents, communities of color, and/or tribal communities—when developing compliance plans. In addition, EPA will allow states to opt into a Clean Energy Incentive Program (CEIP) that rewards renewable energy projects and low-income energy efficiency programs initiated before the first compliance period.
Synapse’s first webinar on this topic focused on the CEIP, addressing questions about resources eligible for CEIP credits, the allocation of credits from states and EPA, and the benefits and risks of participating in the program. The second webinar discussed broader environmental justice issues and states’ requirements during compliance plan submittal. For example, states must provide names of community groups, the state’s method for identifying these groups, and the mechanisms for engaging them.
Environmental Justice and the Clean Power Plan (December 8 webinar slides)
Understanding the Clean Energy Incentive Program (November 17 webinar slides)
On behalf of Save the Sound, Synapse compared recent studies on the need for new and expanded natural gas pipeline infrastructure proposed by Kinder Morgan subsidiary Tennessee Gas Pipeline in Connecticut and surrounding states. Within the context of Connecticut energy demand and climate laws, the team reviewed and synthesized the findings of three separate New England natural gas demand reports released in 2015, examining issues related to compliance with Connecticut’s Global Warming Solutions Act, and placing these findings in the context of expected near- and medium-term capacity and demand of natural gas in Connecticut.
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
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