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 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.
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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 District of Columbia 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
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)
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.
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
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.
The Rhode Island Energy Efficiency & Resource Management Council (RI EERMC) and other stakeholders have begun exploring ways to encourage demand response at residential and small commercial sites in Rhode Island. Synapse provided technical expertise to RI EERMC throughout this collaborative process, first drafting a report that summarized demand response in New England over the previous six years. The report detailed (1) the participation of demand response in the forward capacity market, (2) the major demand response providers working with customers to provide demand response to the wholesale markets, and (3) customers who typically benefit from that partnership. Synapse then helped RI EERMC identify issues to address with its stakeholder group, including opportunities for demand response in Rhode Island and options for pilot project design. The final stage focused on using a consumer technology adoption model to engage these customers.
Demand Response: Scoping the Opportunity for Rhode Island (slide deck)
Technology Adoption for Small Customer Demand Response
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
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.
Synapse was hired by NRDC's Sustainable FERC Project to assist them in convincing PJM staff and stakeholders that their load forecasting process should include a forecast of future energy efficiency. Ultimately PJM staff proposed their own method of including an EE forecast in their load forecasting methodology. Synapse reviewed PJM’s proposed method and welcomed their approach. An initial forecast of solar PV installations has also been included.
On behalf of the Nova Scotia Utility and Review Board, Synapse reviewed the demand-side management plan filed by EfficiencyOne for 2016-2018. Tim Woolf submitted direct testimony to the Board on the appropriateness of the budget and savings levels, addressing affordability, cost-effectiveness screening, and bill impact analyses. Mr. Woolf’s testimony finds that EfficiencyOne’s plan is cost-effective and affordable, and could be expanded to reach higher energy savings levels without resulting in large or undue short-term rate increases.
Synapse, through its subcontractor John Rosenkranz, analyzed and reviewed Elizabethtown Gas’s petition to the New Jersey Board of Public Utilities for the review of its Period Basic Gas Supply Service Rate.
Energy efficiency is widely recognized as an abundant and low-cost option for complying with the requirements of EPA’s Clean Power Plan. Whether states choose a mass-based or a rate-based approach to compliance, energy efficiency should be the primary strategy for complying with the Clean Power Plan. However, not all electric customers have equal access to customer-funded efficiency programs. Concerns about fairness between customers—those who participate in programs and see greater benefits than those who do not—create a barrier to widespread implementation of energy efficiency programs.
Synapse developed a handbook that outlines ten strategies to mitigate concerns about fairness between customers. The handbook—a resource for state legislators, public utility commissions, local governments, program administrators, and other stakeholders—discusses each strategy in detail, including how it promotes fairness, its potential to save more energy, the actions states must take to put the strategy in place, and examples of entities that have already implemented these strategies.
Synapse also released an accompanying factsheet that discusses the key concepts driving these strategies and describes how states can leverage the Clean Power Plan to generate additional funds for energy efficiency programs.
Energy Efficiency and the Clean Power Plan (factsheet)
Energy Efficiency and the Clean Power Plan (December 15 webinar slides)
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