In a lengthy and complex legal proceeding, Entergy is contesting the New York state ruling that closed-cycle cooling is the best technology available for minimizing environmental impacts at Indian Point, and must be installed as a condition for renewal of state and federal operating licenses. Synapse assisted Riverkeeper in preparing for hearings, addressing the question of whether the costs of cooling towers at Indian Point would be "wholly disproportionate" to their benefits, and evaluating the implications of other New York regulations for Entergy's decisions about cooling technologies at Indian Point. Frank Ackerman testified in hearings.
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Rebuttal Testimony of Frank Ackerman Regarding Permanent Fish Protection Outages at Indian Point Energy Center
Synapse critiqued industry claims that a small, sensible change in Food and Drug Administration (FDA) regulations will add billions of dollars to the costs of prescription drugs. Currently, generic drug producers are required to use exactly the same label and warnings as the brand-name version of the same drug; the Supreme Court has held that, as a result, the generic producers cannot be held liable for failure to warn their customers of known drug hazards if the warnings do not appear on the brand-name label. Generic drugs account for most prescriptions filled in the U.S., and brand-name production often ceases when generics enter the market. This often means that the brand-name label, and hence the identical generic labels, are no longer updated when new information is discovered about drug hazards.
FDA proposes to change its rules to allow generic drug producers to update their own labels. The drug industry claims this will cause huge increases in the cost of generic drugs. At the request of the American Association for Justice (AAJ, formerly the American Trial Lawyers Association), Synapse evaluated the costs and benefits of generic drug regulation, and critiqued industry arguments against the FDA rule change.
Synapse and Resource Insight assisted the Maryland Office of People’s Counsel in its evaluation of proposed metrics regarding price mitigation or Demand Reduction Induced Price Effects (DRIPE) in the context of the EmPOWER Maryland cases. The project team analyzed proposals and calculations presented to the Public Service Commission Working Group, and suggested revisions and alternatives as appropriate. Resource Insight’s Paul Chernick presented testimony to the Commission.
Synapse assisted a coalition led by PennFuture with its participation in an initial stakeholder meeting designed to provide feedback to the Pennsylvania Public Utility Commission and the statewide evaluator regarding a proposed design for a demand response program under PA Act 129. Synapse reviewed the scope of the Total Resource Cost test to be used to evaluate the program upon its completion. Project completed August 2014.
Synapse provided litigation support to the Department of Justice in United States v Duke Energy Corp, a case alleging that Duke Energy modified many of its coal-fired electricity units without obtaining the required New Source Review permitting as part of the Clean Air Act and without installing the required pollution controls. Synapse expert witness Bruce Biewald prepared an expert report analyzing PROMOD and similar modeling simulations prepared by Duke Energy and evaluating the anticipated impacts of the modifications on electricity generation. Mr. Biewald then provided assistance to the DOJ in preparation for trial.
As part of its plan to develop a 20 megawatt solar facility in Ludlow, Vermont, Ranger Solar commissioned Synapse to evaluate several aspects of the project’s impacts within the state of Vermont and the greater region. Synapse analyzed the energy and capacity needs of the state; the requirements of utilities in the region to obtain more renewable energy under state policies; and the extent to which the project meets those needs. Synapse also analyzed the project’s impact on economic activity in the state, wholesale markets, customer rates, and greenhouse gas emissions. In March 2017 Ranger Solar received regulatory approval to move forward with the project.
Direct Testimony of Thomas Vitolo on the Need and Economic Benefit of the Proposed Coolidge Solar Project
Synapse performed a feasibility study for Efficiency Maine Trust. The study analyzed the ISO-NE governing documents for real-time demand response and identified possible alternatives to ensure customers in Maine who are willing to provide demand response have the opportunity to do so.
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.
A key benefit of renewable energy is that electricity generated from new renewable resources displaces electricity generated from other types of power plants. In doing so, renewables reduce the consumption of fossil fuel and production of fossil fuel-related carbon dioxide emissions. In the Clean Power Plan originally proposed by EPA in June 2014, this effect was ignored when setting emissions targets for states: EPA’s formula omitted this effect. In the final version of the rule, released August 3, states’ targets do account for emissions displaced by renewable generation.
As part of our ongoing series of webinars on EPA’s Clean Power Plan, Synapse hosted a webinar on how displacement occurs within the electric power system, and what this means for final targets set by EPA as well as states’ compliance with the rule. Panelists included authors of the Synapse report Air Emissions Displacement by Energy Efficiency and Renewable Energy, a survey of evidence that renewable resources and energy efficiency have indeed displaced fossil fuel resources connected to the grid.
Synapse reviewed the incorporation of end-use components into the Nova Scotia load forecasting modeling.
Synapse CEO and founder Bruce Biewald presented on energy efficiency as a resource for compliance with EPA’s Clean Power Plan at the 2015 NASEO Energy Policy Outlook Conference in Washington, DC on February 5. His presentation, part of a panel on privately delivered energy efficiency, included a discussion of how analysis using Synapse’s Clean Power Plan Planning Tool can help to understand and estimate the benefits of energy efficiency as an element of state CPP compliance plans.
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)
To assist Prince Edward Island Regulatory & Appeals Commission in reviewing Maritime Electric's five-year plan, Commission staff sought independent advice on various demand-side management program issues. For the Commission staff, Synapse prepared a comprehensive, best practice report that details key principles of various energy efficiency program and policy requirements, as well as key principles of rate design for encouraging energy efficiency and conservation. This report also provides examples from other jurisdictions and recommendations for how PEI should move forward. Specific topics included in this report are: (1) program planning and review processes, (2) program design, (3) cost-effectiveness screening, (4) multi-year planning and savings targets, (5) cost recovery, (6) shareholder incentives, (7) stakeholder input, (8) evaluation, measurement, and verification, and (9) electricity tariffs to encourage energy efficiency and conservation.
In Massachusetts, municipal light departments have historically had minimal requirements to implement energy efficiency programs in their towns, and only a few offer more than is required by the state commission. As a subcontractor to Galligan Energy Consulting, Synapse assisted in the development of a high-level, statewide efficiency plan that the municipal entities could further develop and implement, including suggested programs, costs, benefits, and rate impacts.
Tim Woolf presented "Energy Efficiency Valuation: Boogie Men, Time Warped, and Other Terrifying Pitfalls" at the ACEEE Conference on Energy Efficiency as a Resource in Little Rock, Arkansas on September 22, 2015.
As a subcontractor for Eastern Research Group, Synapse provided the EPA with technical assistance to update the 2006 Clean Energy-Environment Guide to Action. The guide provides in-depth information about clean energy programs and policies that states use to meet their energy, environmental, and economic objectives. Synapse provided updated research on electricity resource planning and procurement. The 2015 edition is available here.
In January 2015, EUCI hosted "Net Metering 2.0 and Utility Solar Rates," a conference with the goal of exploring rate structures that facilitate meeting solar development goals for consumer adoption, while striking an optimum balance among all solar development stakeholders. Synapse's Joseph Daniel presented on balancing policies to protect consumers in a session focused on integrating solar into the grid without losing assets.
Synapse’s Jeremy Fisher, Patrick Luckow, and Joseph Daniel presented at the 18th Annual Energy, Utility & Environment Conference & Expo (EUEC2015), held February 16 - 18, 2015 in San Diego, California. In the session dedicated to compliance strategies for air policies and regulations, Dr. Fisher presented “EPA’s AVERT: Avoiding Emissions from the Electric Sector through Efficiency and Renewable Energy” with EPA's Robyn DeYoung. Mr. Luckow presented “CO2 Price Forecasting: Planning for Future Environmental Regulations” in the energy policy and finance session. Mr. Daniel presented on "Implementing Net Metering to Meet Policy Objectives" in a session focused on distributed generation.
CO2 Price Forecasting: Planning for Future Environmental Regulations
Implementing Net Metering to Meet Policy Objectives
Synapse helped the Maryland Office of Peoples Counsel evaluate five categories of metrics for smart grid initiatives proposed by BG&E and PEPCO: reductions in energy prices, avoided capacity costs and reductions in capacity prices as a result of reductions in energy use enabled by smart grid initiatives such as peak time rebates (PTR), and reports to customers on their energy usage, and Conservation Voltage Reduction.
Sierra Club retained Synapse to evaluate Kansas City Power & Light’s economic justification for environmental retrofits at the La Cygne Generating Station, for which KCP&L is requesting capital recovery in a case before the Missouri Public Service Commission. The retrofits for La Cygne, which is on the Kansas/Missouri border, were pre-approved by the Kansas Corporation Commission in 2011. After reviewing KCP&L’s original application, modeling files and associated work papers, the monthly status reports on the La Cygne environmental retrofits, and other materials, Synapse found that the original analysis of the retrofits was imprudent and that market conditions have changes significantly in the electric sector in 2011 and 2012, warranting a reevaluation of that analysis.
Surrebuttal Testimony of Rachel Wilson on the Prudence of Environmental Retrofits at KCP&L La Cygne Generating Station
Synapse assisted Sierra Club with its involvement in TVA’s 2015 IRP development process by reviewing and providing comments on TVA IRP materials, and conducting background research and analyses. Synapse provided background research and analyses on the following issues: (a) energy efficiency program potential and assumptions; (b) energy efficiency resource screening methods; (c) public benefits of energy efficiency, including job impacts; (d) IRP best practices, (e) TVA’s scorecard methods, including renewable energy dispatchability and weighting issues with scorecard metrics; and (f) the economic merits of coal power plant retirements. Further, Synapse developed a report on the draft 2015 IRP based on our assessment of IRP assumptions, the draft IRP, and Synapse technical reports.
Maximizing Public Benefits through Energy Efficiency Investments
Review of TVAs Draft 2015 Integrated Resource Plan
EPA’s final Clean Power Plan differs from the version proposed last year in several non-trivial ways. In fact, the basic framework of the rule—the way in which the EPA sets states’ targets for emissions reductions and the options for meeting those targets—has changed. As part of our ongoing series of webinars on the final Clean Power Plan, Synapse presented a webinar on August 18, 2015 that drilled into the details of EPA’s new method for calculating states’ targets and the differences between the seven compliance pathways (of which there were two in the proposed rule).
On August 3, 2015, the U.S. Environmental Protection Agency released the final version of its Clean Power Plan, the agency’s effort to regulate greenhouse gas emissions from power plants built before 2012. Synapse hosted a webinar two days after the final plan was released to provide a first-cut look at how the final rule differs from the rule proposed in draft form a year earlier. Panelists discussed new timelines, targets, and compliance pathways available to states; and presented a primer on the legal framework for compliance plans.
FirstEnergy’s Ohio utilities (Ohio Edison, Cleveland Electric, and Toledo Edison) filed an application before the Public Utility Commission of Ohio seeking approval of an Electric Security Plan (“ESP”) and related Retail Rate Stability Rider (“Rider RRS”). FirstEnergy claims that customers will receive benefits of over $2 billion over the length of the plan due to the Companies’ projections of revenues from capacity and energy market sales. On behalf of Sierra Club, Synapse expert witness Tyler Comings submitted testimony focusing on the assumptions and analysis used by the Companies to support the Rider RRS, and the policy implications and risks associated with the proposed transaction.
Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Second Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Third Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Rehearing Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Recently, there has been a substantial increase in the number of utilities that propose to recover more of their costs through monthly fixed charges rather than through variable rates. Synapse prepared a report for Consumers Union that documents the current trend toward utilities proposing substantial increases in fixed electricity charges, describes the theoretical flaws behind fixed charges, analyzes their impact on consumers, and proposes alternatives.
Synapse and Consumers Union held a webinar on February 10, 2016 based on the report: Caught in a Fix: The Problem with Fixed Charges for Electricity.
Caught in a Fix: The Problem with Fixed Charges for Electricity
Caught in a Fix - Webinar Slides
Synapse provided consulting and strategic services to support Efficiency Maine's participation in the Forward Capacity Market.
The widely cited FUND model of climate economics estimates that climate change will have less serious impacts, and that the optimal policy is to do less, than implied by many other analyses. Synapse's Frank Ackerman together with subcontractor Charles Munitz explored the FUND model, testing combinations of inputs that may illuminate the sources of FUND's distinct forecasts.
Southern Environmental Law Center retained Synapse to review Dominion Virginia Power’s application for a Certificate of Public Convenience and Necessity for its proposed Greensville County Power Station, a new natural gas combined-cycle plant. Synapse’s analysis found that the Company’s need analysis overstated its electric load and did not give appropriate consideration to alternative resource choices. On behalf of environmental respondents, Rachel Wilson submitted testimony to the Virginia State Corporation Commission demonstrating that Dominion overstated the need for the Greensville NGCC and recommending that the Commission deny the Company’s petition for a CPCN and an associated rate increase.
Synapse assisted the State of Maine Office of the Public Advocate in reviewing a petition filed by GridSolar. The petition has three key proposals: 1) the Smart Grid Coordinator should provide nine services that fall into two broad groups (NTA-related services and Customer-facing services), 2) the Smart Grid Coordinator should be established as a single, state-wide regulated utility, and 3) GridSolar should be selected as that Smart Grid Coordinator. Synapse developed testimony that addressed whether it is in the public interest to have a single, state-wide, third-party Smart Grid Coordinator established as a regulated utility and whether it is in the best interest of the public to select GridSolar to be that Smart Grid Coordinator.
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