On behalf of the District of Columbia Department of Energy and Environment (DOEE), Synapse provided expert witness testimony regarding Pepco’s proposed multi-year rate plan and performance incentive mechanisms. Synapse also drafted comments in response to the Commission's Notice of Inquiry regarding implementation of the CleanEnergy DC Omnibus Amendment Act of 2018, which requires the Commission to consider the “effects on global climate change and the District’s public climate commitments.”
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GD2019 04 M: DC DOEE Comments Responding to Notice of Inquiry
Direct Testimony of Courtney Lane in Formal Case No. 1156
Rebuttal Testimony of Courtney Lane in Formal Case No. 1156
Surrebuttal Testimony of Courtney Lane in Formal Case No. 1156
Supplemental Testimony of Courtney Lane in Formal Case No. 1156
On behalf of the Eastern Environmental Law Center (EELC), Synapse and subcontractor John Rosenkranz conducted a comprehensive assessment of National Grid’s Capacity Report released February 24, 2020. National Grid's Capacity Report detailed gas peak demand forecasts through the winter of 2034/35, modeling both High Demand and Low Demand scenarios. The report then assessed various long-term gas solutions to fill these gaps. These potential solutions included various large-scale gas infrastructure projects such as the NESE pipeline and LNG facilities, as well as a “No Infrastructure” option which solely relies on additional demand-side resources.
Our analysis found various errors in National Grid’s assessments of the rate of customer conversion from oil to natural gas for the load forecasts, expected levels and costs of energy efficiency and heat pumps under existing or expanded policies and programs, and gas supply resources. The report concludes that corrections to these errors and appropriate treatment of demand-side measures, with or without small changes in National Grid’s supply planning assumptions, eliminates the need for any of the large-scale infrastructure investments examined in the Capacity Report.
On behalf of Earthjustice, Synapse reviewed the U.S. EPA's benefit-cost analysis of changes to the proposed power plant effluent limitations guidelines (ELG). Synapse created an expert report that Earthjustice submitted as part of its official comments on the proposed rule modification.
The purpose of this report is to (1) evaluate the proposed changes to the 2015 ELG rule; (2) review the four options the EPA lays out for compliance (focusing on Options 2 and 4); (3) review the EPA’s benefit cost analysis (BCA); (4) critique the EPA’s analysis and results; and (5) provide recommendations on how the EPA should structure its BCA and which compliance option it should recommend.
On behalf of Environmental Defense Fund, Synapse conducted a benefit-cost analysis of proposed emissions rules drafted by the New Mexico Environment Department. These proposed rules curb emissions of volatile organic compounds (VOCs) from the oil and gas industry in New Mexico. The analysis compared implementation costs to four types of benefits to the state of New Mexico: sales from newly captured gas, avoided costs related to human health impacts, avoided nonattainment costs of reduced GHG emissions, and the global societal benefit of reducing methane emissions into the atmosphere. The report presents three different approaches to the benefit-cost ratio (BCR) of the proposed rules (e.g., New Mexico BCR, National BCR, and Global BCR) – all of which are cost-effective according to the Synapse analysis.
On behalf of the Natural Resources Defense Council, Synapse is providing technical and policy support in a number New York Public Service Commission (PSC) proceedings, including the Reforming the Energy Vision (REV) initiative. This work includes review, comments, and analysis of policies and targets for energy efficiency and other distributed energy resources, to ensure that New York meets its climate, energy, and low- and moderate-income energy affordability goals. Project ongoing.
The 100PercentCT Project developed by People’s Action for Clean Energy (PACE) supports the transition to a clean energy economy in Connecticut. The project’s primary function is to conduct energy analyses to help inform individual towns and the State of Connecticut about opportunities to achieve 100 percent renewable energy for the buildings and transportation sectors. PACE developed the Town Energy Analysis model—an in-house, techno-economic tool—to inventory energy use and emissions in Connecticut towns and evaluate strategies to transition to renewable energy.
Synapse performed an in-depth review of PACE’s Town Energy Analysis model to identify opportunities to improve upon and expand the model. We evaluated the modeling methods, sectors, and scope included in the energy analysis, as well as the inputs and data sources used. We compared PACE’s model alongside 10 publicly available energy and climate modeling tools to identify opportunities to align the Town Energy Analysis model with current best practices in energy and greenhouse gas accounting and in identification of mitigation opportunities.
Synapse issued a report to PACE presenting our review of the Town Energy Analysis model. First, our report summarizes the energy and climate modeling tools used to establish current energy and climate planning best practices for analytical models. Next, we validate PACE’s model and identify specific changes to improve key data, inputs, methods, and assumptions used in the model. We conclude by identifying additional modeling approaches, clean energy strategies, market segments, and energy impacts for the possible inclusion within PACE’s Town Energy Analysis model.
Synapse supported the Natural Resources Defense Council (NRDC) with analysis of a commercial electric vehicle time-of-use (TOU) rate that was proposed by Duquesne Light in Pennsylvania in a regulatory proceeding. Synapse calculated bill impacts for small and medium commercial and industrial (C&I) customers, aiming to understand how charging non-EV load on the EV TOU rate impacts the bills of C&I customers, relative to the default flat rate. Synapse also compared the impact of the TOU rate on EV charging cost per mile relative to the cost of gasoline per mile for a comparable internal combustion engine vehicle. The analysis examined several types of small and medium C&I customers, including hotels, office buildings, and warehouses, as well as DC fast-charging load. The final deliverable was a slide deck that was used as an exhibit in NRDC's testimony. The testimony is filed here.
Synapse, subcontracting to Eastern Research Group, supported the Maine Climate Council in modeling economy-wide decarbonization pathways for the state that met the state’s goal of reducing emissions 45 percent by 2030 and 80 percent by 2050 below 1990 levels. Synapse analyzed the transportation, buildings, and electric power sectors using its suite of electrification and decarbonization models. Synapse used its EV-REDI and Building Decarbonization Calculator (BDC) tools to determine trajectories for the adoption of non-emitting electric vehicles (EV) and heat pumps needed to reduce emissions in line with the state’s 2030 and 2050 targets. Using these models, we also calculated the resulting electricity consumption, which we used as an input into the electric sector modeling to ensure that enough clean energy would be generated to meet the growing needs of an electrified economy. Synapse used the EnCompass model to develop a scenario in which Maine’s renewable portfolio standard increased to 100 percent by 2050. Synapse also evaluated reasonable emissions reduction trajectories in other sectors of the economy. The resulting analysis illustrated some of the tradeoffs between reducing emissions through different technological pathways. Synapse energy sector modeling informed the Maine Climate Council's recommendations published in the final report "Maine Won't Wait: A Four-year Plan for Climate Action."
On behalf of Sierra Club, Synapse submitted testimony supporting electric system transformation within an APS rate case, including support for enhanced customer access to data, opposition to formula rates, and recommendations for evaluation of securitization.
As a continuation of previous work, Synapse provided counsel to the NS UARB with technical consulting services on demand side management (DSM) issues. As part of the project, Alice Napoleon submitted evidence on EfficiencyOne’s proposed 2020-2022 Demand Side Management Resource Plan. In addition, Synapse conducted analysis and provided comments on proposals to modify the DSM rate and bill impact model, to develop a methodology for calculating avoided transmission and distribution system costs, and to design a program to target DSM at locations where distribution system investment can be avoided. Synapse also analyzed and critiqued a DSM potential study, and an analysis of potential bias in the program administrator's projections of energy savings and spending.
Synapse Comments on EfficiencyOne Performance Alignment Study - M09096
Synapse Comments on EfficiencyOne's 2019 Rate and Bill Impact Analysis and Model - M09471
A new report produced by Synapse Energy Economics, the Regulatory Assistance Project, and Community Action Partnership—with support from the Robert Wood Johnson Foundation—takes an in-depth look at the disparate impacts electric and natural gas infrastructure have on economic, social, and health outcomes—and consider how to ensure that a clean-energy future is a more equitable future. The report finds a variety of opportunities for policymakers, including policies to make energy more affordable for vulnerable communities, expand access to energy, reduce environmental hazards, and create jobs in the clean energy transition. The report also includes case studies from municipalities, states, and regions across the country that are working to achieve these goals. The small city of Bloomfield, Iowa, has taken charge of its energy future, transforming its approach to resource planning, investing in efficiency and solar power, and spurring local development. In Ohio, a statewide arrearage management program provides a model for protecting customers from utility shutoffs. In Minnesota, Xcel Energy and the state’s utility regulators are working together to implement performance-based regulation, with benchmarks for improving customer service quality and workforce diversity. And the 10 northeastern states that participate in the Regional Greenhouse Gas Initiative are reducing carbon dioxide emissions (and other pollution) from power plants, improving environmental conditions and community health outcomes. This report highlights these successes and provides policymakers with insights into how to create a successful – and economically inclusive – transition to a clean energy future.
For further insights on this report, read our blog post here.
On behalf of the Sierra Club, Erin Camp, PhD wrote expert witness testimony evaluating Dominion Energy’s electric vehicle (EV) Smart Charging Infrastructure Pilot Program (“Pilot Program”), focusing on the light-duty EV stock growth projection for Dominion’s service territory. The EV stock growth projection, which was used to calculate the number of EV charging stations eligible for rebates in the Pilot Program, underestimated the likely adoption of light-duty EVs in the Company’s service territory. Dr. Camp’s analysis found that, by 2030, the number of registered EVs in the Dominion’s service territory is likely to be double what was predicted by the utility. Her testimony encouraged the utility to recalculate the forecasted EV market and to update the estimated number of required EV charging stations. Dr. Camp also explained that encouraging EV adoption with a well-designed utility program can put downward pressure on rates and benefit all consumers in Dominion’s service territory. Further, a well-designed program will also ensure that the benefits of transportation electrification are equitably distributed to all customers, including low- and moderate-income customers, by improving access to clean, electric transportation options in the form of electric transit (i.e., buses) and charging stations to support EV charging at multi-family buildings.
The FERC approved the Atlantic Coast Pipeline (ACP) in 2017. Project owners Duke and Dominion filed a certificate for a construction extension with FERC on June 16, 2020. On behalf of the Southern Environmental Law Center, Synapse assessed the projected demand for new gas used for electric generation, estimating the “maximum demand for new gas” on a peak winter day in Dominion’s and Duke’s service territories. We examined public IRPs, new policies in Virginia and North Carolina that will lower CO2 emissions in the electric sector, and public documents related to the utilities’ internal emission reduction goals. We used that data to build spreadsheet models to assess maximum future gas demand on a winter peak day. Our analysis demonstrates that the need for new gas-fired generating resources originally anticipated by Duke and Dominion has not and will not materialize, thus negating the utilities’ claimed need for the ACP.
Earlier Synapse work on EV Rates, completed on behalf of NRDC, can be found here.
Electric Vehicles are Driving Electric Rates Down - June 2019 Update
Synapse is assisting Energy Outreach Colorado in responding to Public Service Colorado’s time-of-use (TOU) rate implementation proposal. TOU rates have the potential to provide customers with greater control over their bills and reduce system costs. However, to be successful, TOU rates must be implemented thoughtfully and with sufficient customer education, protections, and choice. Synapse’s testimony focuses on best practices for implementing TOU rates and particularly for ensuring that low-income customers are adequately protected and are not subject to rates that would be disproportionately burdensome.
Cross-Answer Testimony and Attachments of Tim Woolf Regarding Need for Customer Opt-Out Provision in PSCo's TOU Rate Plan
Synapse was retained to review applications by Indiana electric utilities to recover “lost revenue” resulting from lower than expected commercial and industrial sales due to COVID-19. Synapse's expert witness Cheryl Roberto recommended no recovery of lost revenue to The Indiana Utility Regulatory Commission. The Commission ultimately ruled against recovery of lost revenue; consistent with Synapse recommendations.
Synapse was retained by Sierra Club to review a request by Evergy Metro, Inc. and Evergy Missouri West, Inc. to recover “lost revenue” resulting from lower than expected commercial and industrial sales due to COVID-19. Synapse expert witness Cheryl Roberto testified before The Missouri Public Service Commission, recommending no recovery of lost revenue.
Synapse assisted the Sierra Club with evaluating Dominion’s 2020 Virginia IRP and modeling alternative scenarios demonstrating the cost effectiveness of clean energy generation and coal retirements. Synapse modeled an optimized Virginia Clean Economy Act (VCEA) compliant scenario in EnCompass that resulted in lower emissions and lower costs than Dominion’s preferred plan. Rachel Wilson sponsored testimony describing how the Synapse scenario eliminated unnecessary gas capacity additions that Dominion fixed in its modeling, and showed that accelerating retirements of certain coal units by increasing solar generation capacity would save ratepayers billions of dollars. In addition, Synapse reviewed Dominion’s position regarding the PJM Minimum Offer Price Rule (MOPR) and the Fixed Resource Requirement (FRR) alternative to participating in the PJM capacity market under the MOPR. Jason Frost sponsored testimony describing how the MOPR will increase the costs of meeting state clean energy goals and require Dominion to retain unnecessary legacy fossil fuel powered generation by not counting renewable capacity. Mr. Frost’s testimony also discusses how the FRR presents a way to avoid the negative impacts of the MOPR, and can reduce consumer costs by avoiding the need to pay for legacy fossil fuel capacity that is no longer needed.
Direct Testimony of Jason Frost in Case No. PUR-2020-00035
The Maryland Office of People’s Counsel (OPC) retained Synapse to provide expert witness testimony on the benefit-cost analysis (BCA) Baltimore Gas and Electric Company (BGE) filed for its electric vehicle program portfolio as part of its Multi‐Year Plan.
Surrebuttal Testimony of Courtney Lane in Case No. 9645
Surrebuttal Testimony of Cheryl Roberto in Case No. 9645
On behalf of the Natural Resources Defense Council, Synapse prepared a sweeping analysis and developed recommendations for New York to consider as the state begins a transition away from natural gas in order to meet its ambitious carbon reduction requirements. The report is being filed in the New York Public Service Commission's recently opened natural gas planning process docket.
This report is part of Synapse's continued support for New York State's "Reforming the Energy Vision" (or "REV") initiative. Find more of Synapse's work completed on behalf of NY REV here.
Electricity generation from Duke Energy, Dominion Energy, and Southern Company utilities collectively represent 12.4 percent of U.S. power sector CO2 emissions – equivalent to 4.2 percent of total U.S. CO2 emissions. While all three utilities have announced plans to decarbonize their electricity generation by 2050 in order to meet climate targets, a deeper look into their generation portfolios and plans reveals that all three utilities are on track to fall short of their emissions reduction commitments.
On behalf of the Climate Majority Project, Synapse investigated the companies’ current plans for fleet decarbonization. We made the following recommendations to help ensure a path to reach climate targets by 2050: (1) develop science-based CO2 trajectories upon which all future plans and actions should be rooted; (2) conduct robust retirement and replacement analysis to determine the least cost path to retire each company’s existing fossil fleet and replace it with alternative zero-carbon portfolios; (3) invest in renewables and demand-side resources to meet future resource needs; (4) invest in grid-modernization solutions in tandem with retirement of existing resources and development of renewables; and finally (5) evaluate and plan for changing system needs, including load growth driven by electrification instead of traditional steady demand.
Synapse worked on behalf of Labor Network for Sustainability to analyze the economic benefits of improving energy, water, and transportation infrastructure in Massachusetts through increased state, municipal, and public investment. First, we identified spending gaps between existing investment plans for these three sectors and the level of investment needed to bring the sectors to a state of good repair. We used infrastructure needs reports, gap analysis studies, and state policy goals to identify the spending gaps. Next, we calculated the employment impacts of improving this infrastructure through increased investment between 2020 and 2030. We used IMPLAN, an industry-standard job impact model, to convert annual spending levels into annual job creation. We produced a final report summarizing the results for all three sectors as well as a selected set of city-specific case studies.
Engaged by Apogee Climate and Energy Transitions, Synapse reviewed the publicly available documents associated with the Kentucky Municipal Energy Agency’s 2020 integrated resource plan process. Synapse provided the client with a memo detailing its concerns with KYMEA’s IRP process, its forecast, capacity and energy obligations, contractual options, and provided short-, medium-, and long-term recommendations. Dr. Thomas Vitolo provided public comments to KYMEA on September 24, 2020.
On behalf of the Sierra Club and Natural Resources Defense Council, Synapse provided technical support and expert witness testimony in California docket A19-11-019. Synapse conducted a bill impacts analysis for customers in three different climate zones who might electrify their home on Pacific Gas & Electric's proposed E-ELEC time-of-use rate. Erin Camp, PhD, authored expert witness testimony, demonstrating that electrifying on the proposed E-ELEC rate is not likely to be economical for customers who live in multi-family buildings, especially those customers who are low-income. In her testimony, Dr. Camp advocated for a separate, additional electrification time-of-use rate for all low-income customers in PG&E's service territory to alleviate the barrier to electrifying for this vulnerable customer group.
This project is ongoing and is currently in settlement discussions.
The Maryland Public Utilities Article (“PUA”) § 7-216 established the Maryland Energy Storage Pilot Program. The pilot program required each distribution utility to submit at least two energy storage project applications for Commission review. Synapse was retained by the Maryland Office of People's Counsel to assist with reviewing the applications and to provide technical analysis and recommendations. With Synapse’s assistance, OPC prepared extensive discovery requests for each of the four utilities, seeking information and data on their energy storage applications.
Synapse thoroughly reviewed each pilot energy storage project application. The review included an assessment of the proposed projects in three general areas. Synapse's Courtney Lane led the economic and ratemaking analysis of the projected costs, savings, and benefits of the proposed projects. Dr. Erin Camp led the assessment of environmental impacts and Dr. Steve Letendre addressed wholesale market issues. Synapse analysis raised concerns about wholesale market revenue risks, deferral value calculations, and emissions impact methods. Synapse expert witnesses participated in the Maryland Public Utilities Commission hearing held on July 13, 2020, to present to the Commission Synapse's analysis of the storage project applications.
The Massachusetts Department of Energy Resources retained Synapse and subcontractor DNV GL to produce a comprehensive assessment of mobile energy storage systems and their use in emergency relief operations. The study explored the landscape of available mobile energy storage systems, which are roughly divided into towable units and self-mobile systems in the forms of various electric vehicle (EV) platforms. Mobile energy storage systems may be uniquely capable of enhancing energy resilience in response to severe weather events and associated outage conditions. The study found that mobile energy storage systems can be self-mobile electric vehicles (light-duty vehicles, vans, or buses) or towable (towable or transportable via semi-trailer truck). This study provided a comprehensive assessment of mobile energy storage systems, their use in emergency relief operations, and their use on typical (non-outage) days. Specifically, this report addressed four fundamental questions: state-of-the-art, usage on typical days, opportunities and challenges to deploy in response to outages, and potential advantages over stationary battery energy storage systems.
The final report, Mobile Energy Storage Study: Emergency Response and Demand Reduction, is available on the Department of Energy Resources website.
Synapse worked for the National Efficiency Screening Project (NESP) with E4TheFuture as coordinator to develop a National Standard Practice Manual for Benefit-Cost Analysis of Distributed Energy Resources (NSPM). The purpose of the NSPM is to improve the way that utility customer-funded distributed energy resources are evaluated for cost-effectiveness throughout the United States, and to inform decision-makers regarding which resources are in the public interest and what level of investment is appropriate. The NSPM provides a set of policy-neutral, unbiased, and economically sound principles, concepts, and methodologies to support benefit-cost analysis for distributed energy resources, including: energy efficiency, demand response, distributed generation, distributed storage, and building and transportation electrification. Synapse's primary role was as the lead technical consultant. The manual was developed with a Drafting Committee of five experts and incorporated input from a nation-wide Review Committee. The NSPM is available here.
Using hourly, publicly available data, Synapse examined the impact of solar on energy benefits. From 2014-2019, behind-the-meter solar created $1.1 billion in energy benefits in the six New England states. These include savings resulting from purchasing less electricity, as well as savings due to lower overall electricity prices. We estimate that solar contributed to $87 million in public health benefits, and reduced CO2 emissions by 4.6 million metric tons, equivalent to taking one million cars off of the road.
Synapse provided expert advice on and analysis of energy efficiency programs offered by New Jersey's Clean Energy Program for the New Jersey Division of Rate Counsel. We reviewed, analyzed, and commented on various energy efficiency-related matters, including the state-administered programs’ designs and budgets, avoided energy supply cost estimates, cost-benefit analyses, energy savings protocols updates, and fiscal year budget proposals. We also reviewed and commented on New Jersey Energy Master Plans, a three-year energy efficiency program plan called the Comprehensive Resource Analysis, and various proposals associated with the new energy efficiency program framework including program delivery structure, program design, performance incentives, and cost recovery.
Of all U.S. states, Florida will feel the largest direct impacts from climate change. Given the City of Orlando’s vulnerability to climate impacts, Mayor Dyer and Orlando City Commissioners commitment to 100 percent renewable energy by 2050 was a critical move. Yet Orlando’s electric utility, the Orlando Utilities Commission, still relies almost entirely on fossil fuels to supply the City’s electricity. The City is currently conducting an integrated resource planning exercise to determine the future of its electricity system; this study focuses strongly on fossil resources and includes an evaluation of whether to keep the Stanton Energy Center online, convert the units to gas, or retire the plant. In response to the utility’s IRP exercise, Synapse conducted a study on behalf of the First 50 Coalition to evaluate an alternative renewable and clean energy portfolio that can provide the City with the energy and capacity it needs at a lower cost and lesser environmental impact than the fossil heavy system that the City’s IRP will propose.
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