Synapse provided the Office of the People's Counsel with assistance in evaluating PJM's proposed Reliability Pricing Model (RPM) for capacity markets. On behalf of DC OPC and other consumer advocates in the PJM wholesale power system, Synapse reviewed, proposed modifications, and intervened in a contested process at FERC to determine the final design of the RPM capacity market. Synapse provided assistance to DC OPC in all phases of the review, comments, technical conferences, and settlement processes, and our efforts helped secure modifications to the model that will save state ratepayers in PJM hundreds of millions of dollars annually. In addition, Synapse assisted the Office with transmission planning for economic and reliability upgrades (including cost allocation).
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Synapse was retained to analyze and critique NSPI's application for an air emissions strategy to meet Provincial emission compliance regulations. Our focus was upon the alternatives and methodology used by NSPI to determine its preferred option for SO2 and NOX reduction. We reviewed the Company's STRATEGIST model runs.
Supplemental Evidence Regarding the Review of NSPI Emissions Compliance Plan
Synapse reviewed SIGECO's (Vectren's) environmental compliance plan and prepared testimony addressing system planning, the proper role of demand-side management and renewables in compliance planning, and the need to anticipate climate policy and carbon prices. Synapse's analysis and recommendations are presented in the testimony of Bruce Biewald in Indiana Utility Regulatory Commission Cause No. 42861.
Synapse evaluated the potential for developing better alternatives for moving electricity produced by renewable technologies from the San Diego County/Imperial County/Baja region into San Diego than the new 500 kV transmission line proposed by San Diego Gas & Electric.
Synapse evaluated the fairness of Empire Electric’s proposed rate treatment of off-system sales and consideration of a fuel clause adjustment. Synapse critiqued Empire’s modeling of fuel costs and projections of natural gas prices as part of a proceeding before the Missouri Public Service Commission and supported expert testimony before that commission. Project completed in November 2006.
Synapse evaluated the fairness of Kansas City Power and Light’s proposed rate treatment of off-system sales. KCPL proposed an unorthodox accounting treatment allocating “margins” or profit with an “Unused Energy” allocator. Synapse provided support for expert testimony before the Missouri Public Service Commission. Project completed in November 2006.
Synapse investigated a number of issues in a rate case: 1) whether Arizona Public Service’s (APS) acquisition of the Sundance Generating Station was prudent; 2) whether the amounts that APS requested for Operating & Maintenance expenditures (“O&M”) for the PWEC Units and the Sundance Plant were reasonable; and 3) the generation and associated costs included in APS’ base rate application. Synapse found that APS’ acquisition of the Sundance Plant was reasonable and prudent. However, we found that the Company’s requested power plant O&M was unreasonably high and should be reduced for both plants. Project completed in February 2006.
Direct Testimony of Rick Hornby Regarding the Audit of the Fuel and Purchase Power Practices of the Arizona Public Service Company
Surrebuttal Testimony of David Schlissel Regarding the Audit of the Fuel and Purchase Power Practices of the Arizona Public Service Company
Surrebuttal Testimony of Rick Hornby Regarding the Audit of the Fuel and Purchase Power Practices of the Arizona Public Service Company
Synapse evaluated the potential benefits and costs associated with the deployment of Broadband Over Power lines (BPL) in a utility’s service territory. The potential benefits of BPL include the ability to use the existing power lines and the wiring inside homes and other buildings to offer enhanced energy services and load control, to facilitate the use of distributed generation, for automatic meter reading, to provide internet and other informational services to customers, and for increased system monitoring and outage detection. Project completed in March 2006.
Synapse was asked to evaluate alternatives to the Broadwater LNG import facility, proposed as a floating storage and regasification facility to be located in Long Island Sound. Synapse concluded that the region does not have a pressing need for a new baseload resource to provide natural gas, and the region's energy needs for the next decade can readily be met through energy efficiency, implementation of existing renewable energy goals, expanded use of combined heat and power, and repowering of existing power plants. Finally, we found that there are other options for increasing gas supply to the region which would be far preferable to the Broadwater proposal. The most promising of these includes two LNG import facilities already under construction in Eastern Canada, together with the planned expansion of the Maritimes and Northeast pipeline from Eastern Canada into the northeastern United States. Project completed in February 2006.
Synapse evaluated the reasonable costs of decommissioning the Diablo Canyon, San Onofre, and Palo Verde nuclear power plants. Synapse recommended significant reductions in the annual decommissioning costs that needed to be collected from ratepayers. The case was settled with the companies agreeing to substantially reduce their requested annual decommissioning cost collections. Project completed in May 2006.
Synapse provided technical and managerial support to the Cape Light Compact as part of the Compact’s investigation of cooperative business models that may assist the Compact in furthering its goals. Project completed in November 2006.
This report is designed to assist utilities, regulators, consumer advocates and others in projecting the future cost of complying with carbon dioxide regulations in the United States. These cost forecasts are necessary for use in long-term electricity resource planning, in electricity resource economics, and in utility risk management.
After a Technical Conference in February 2006 on PJM capacity market and reliability issues, FERC provided a comment period for parties to make supplemental statements. Synapse assisted a broad coalition of PJM Members (Coalition of Consumers for Reliability, CCR) in developing Comments. Synapse also provided an affidavit from Ezra Hausman that described concerns with PJM's process for establishing the "cost of new entry" (CONE) for a typical peaking unit. This specific project is part of a larger on-going effort that assists the Pennsylvania Office of Consumer Advocate with PJM wholesale market and bulk power transmission system issues. These Comments were filed in FERC Dockets ER05-1410-000 and EL05-148-000. Project completed in June 2006.
RPM 2006: Windfall Profits for Existing Base Load Units in PJM
Affidavit of Ezra Hausman for FERC Technical Conference on RPM
Post-Technical Conference Comments on FERC Technical Conference on RPM
Pre-Conference Comments on FERC Technical Conference on Proposed Variable Resource Requirement (VRR) Curve in PJM
Post-Technical Comments on FERC Technical Conference on Proposed Variable Resource Requirement (VRR) Curve in PJM
Synapse reviewed the gas supply strategy and proposed rate recovery of Connecticut Natural Gas. Project completed in December 2006.
Synapse was asked by the United States EPA to develop content for the EPA's Clean Energy Website on the calculation and evaluation of displaced pollutant emissions resulting from energy efficiency and renewable energy initiatives. The website content includes a description of several approaches that could be used to calculate displaced emissions, as well as descriptions of their applicability, resource requirements, and precision. The product is to be available as a "decision support" tool for anyone involved in energy efficiency or renewable energy projects to help them assess the emissions benefits of their efforts. Project completed in April 2006.
Synapse was asked to provide prefiled testimony in a 248 proceeding (Certificate of Public Need) on behalf of a private sector wind developer, outlining the economic and environmental benefits of a proposed wind farm in Deerfield, Vermont. Synapse evaluated the need for new energy resources in Vermont, the demand for renewable energy to fulfill state Renewable Portfolio Standards in the region, and the economic benefits of clean energy and displaced emissions. In addition, Synapse projected project costs and revenues to demonstrate the economic viability of the proposal. Project completed in March 2006.
Synapse was asked to provide prefiled testimony in a 248 proceeding (Certificate of Public Need) on behalf of Catamount Energy, Inc., outlining the economic and environmental benefits of a proposed wind farm in Glebe Mountain, Vermont. Synapse evaluated the need for new energy resources in Vermont, the demand for renewable energy to fulfill state Renewable Portfolio Standards in the region, and the economic benefits of clean energy and displaced emissions. In addition, Synapse evaluated how the proposed project conformed to the Vermont Electric Plan. Project completed in April 2006.
Synapse was retained to assist the Arkansas Public Service Commission Staff on issues related to electric policy initiatives on both a state and regional level. Specific tasks included a review of the proposed purchase of a merchant generation facility by the Arkansas Electric Cooperative Corporation; a review of the Southwest Power Pool’s application to be named the regional transmission provider; and an analysis of regional energy planning processes. Project completed in May 2006.
Surrebuttal Testimony Regarding Review of Wrightsville Facility Purchase
Bruce Biewald presented “Electricity Price Increases: Causes, Effects, and Solutions” at the Restructuring Roundtable on May 19, 2006. The presentation focused on the electricity price increases for small customers in New England.
Synapse advised clients in Illinois on alternatives for procuring power to serve default customers after the “transition period” provided for in the State’s restructuring law. Synapse presented testimony addressing a proposal by Commonwealth Edison (ComEd) to use a clearing price auction to procure wholesale power for default customers.
We evaluated the Company's proposal, examining issues of market power in the wholesale electricity markets, market power in retail provision of electricity, acquisition of generation supply, and the management of a resource portfolio to provide bundled generation service to residential and small commercial customers.
We found that, while offering hypothetical benefits to customers, overall the proposal was too narrowly tailored, failed to provide necessary consumer protections, and cut off Commission review of a broad range of options that should be considered as Illinois emerges from the transition period.
Additionally, Synapse proposed alternatives for how the proposed auction process could be improved, should the Commission decide to authorize a similar mechanism to that proposed by ComEd. Testimony was presented before the Illinois Commerce Commission by witnesses Fagan and Steinhurst in docket 05-0159. Project completed in August 2006.
Illinois Post-2006 Procurement Process: How to Serve Bundled Utility Service Customers ‒ Paper
Direct Testimony of William Steinhurst Evaluating Electricity Procurement for Serving Retail Load in Illinois
Direct Testimony of Robert Fagan Evaluating Electricity Procurement for Serving Retail Load in Illinois
Rebuttal Testimony of William Steinhurst Evaluating Electricity Procurement for Serving Retail Load in Illinois
Rebuttal Testimony of Robert Fagan Evaluating Electricity Procurement for Serving Retail Load in Illinois
Rebuttal Testimony Exhibits of Robert Fagan Evaluating Electricity Procurement for Serving Retail Load in Illinois
Rick Hornby, Ezra Hausman, and Anna Sommer presented “Electricity Supply Prices in Deregulated Markets – The Problem and Potential Responses” at the NASUCA Mid-Year Meeting on June 13, 2006.
Synapse participated in a collaborative process to develop energy efficiency programs for Nevada Power Company and Sierra Pacific Power Company. The work included developing policies to support utility energy efficiency programs, developing mechanisms to account for the environmental and economic benefits of energy efficiency, and designing energy efficiency programs with an emphasis on low-income programs. Project completed in August 2006.
Bruce Biewald presented “Energy Portfolio Management Tools and Resources for Regulators” at the NARUC Annual Convention in Miami, Florida on November 15, 2006. The presentation draws from Synapse’s 2006 report Energy Portfolio Management: Tools and Resources for State Public Utility Commissions, prepared for the National Association of Regulatory Utility Commissioners (NARUC), the Energy Foundation, the Department of Energy, and NYSERDA. The report describes portfolio management; data, models, and tools for portfolio management; expertise and staffing for managers and regulators; next steps for regulators; and portfolio management activities in selected states.
Synapse prepared a high level thought paper, presenting the important issues and trends in the energy sector in the Northern Forest Region, a 34 county area stretching from Oswego, NY, across northern Vermont and New Hampshire, to eastern coastal Maine. The paper was written to be thought provoking, to raise critical issues and opportunities that will frame stakeholder dialogue, further analytical study and decision-making for the next phases in the development of the economic adjustment strategy, and to identify and choose among sustainable development options and recommendations in the Northern Forest region. It introduced the important issues, trends, priorities and realities of the energy sector in the 34-county region and set them in context with energy issues and trends from relevant regions elsewhere in the nation. The paper was future oriented, synthesizing key issues and concepts drawn from data and the conclusions of previous analytical work, including detailed economic modeling studies previously conducted by Synapse to measure employment and air pollution impacts of regional strategies for renewable energy and energy efficiency. Project completed in May 2006.
Synapse assisted Office of the People's Counsel for the District of Columbia Staff in the development of positions on various issues in EPAct 2005. Project completed September 2006.
Synapse evaluated the purchases and sales transactions of Public Service of Indiana; in particular, the treatment of those transactions under the "Joint Generation and Dispatch Agreement" under which the Cinergy system operated until April 2005. The results of an initial evaluation were presented in a “verified statement” of Bruce Biewald filed with the Indiana Utility Regulatory Commission in Cause No. 42359. Subsequently, more in-depth evaluations were conducted and those results were presented in the testimonies of Robert Fagan filed with the Indiana Utility Regulatory Commission in Cause Nos. 41954, 42895, and 38707 FAC 61S1. Project completed in February 2006.
Proposed Termination of the Cinergy Operating Agreement
Synapse performed a costs and benefits assessment of one part of proposed legislation to increase the system benefit charge for energy efficiency spending in Maine from 1.4 mils/kWh to 3.0 mils/kWh. Bob Fagan of Synapse testified before the Utilities and Energy Joint Committee of the Maine legislature on the issue. Synapse demonstrated the net economic benefits of increasing the charge and urged the committee to pass the legislation. Project completed in March 2006.
Synapse provided research and consulting support to PSC Staff in the preparation of an energy policy study mandated by an Executive Order of the Governor. Project completed in April 2006.
Bruce Biewald presented “Forecasting and Using Carbon Prices in a World of Uncertainty” at the Electric Utilities Environmental Conference in Tucson, Arizona in January 2006.
In 2006, the Illinois Commerce Commission (ICC) voted to allow Commonwealth Edison (ComEd) to use an auction system to purchase power. In preparation for Illinois’ first auction in January 2007, Synapse performed market analyses to forecast the auction’s likely results. In performing this analysis, Synapse considered the various components that comprise electricity prices, including load cycles, capacity costs, ancillary services such as spinning reserves, anticipated congestion costs or costs of FTRs to hedge congestion risk, other risk costs, and price effects of the PJM Reliability Pricing Model (RPM). Project completed in September 2006.
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