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 Tuscon 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.
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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?"
Synapse reviewed ISO New England’s Operational Fuel Security Analysis (OFSA) study published in January and compared the model results with alternative scenarios suggested by New England stakeholders. The report shows how assumptions about demand for energy (electric and gas) and variations in supply resources might impact grid operations and reliability during an extreme winter in 2024/25. The report finds that using reasonable assumptions about demand and supply resources show minimal grid operation concerns and no rolling blackouts. This finding is starkly different from the ISO’s conclusions in its January OFSA study.
Our report was prepared for Conservation Law Foundation, with support from the Barr Foundation, on behalf of a group of NEPOOL participants that requested that additional scenarios be modeled as part of ISO New England’s OFSA.
Maintaining Reliability Under Extreme Conditions: Understanding ISO New England's Operational Fuel Security Analysis
Synapse was awarded a Conservation Applied Research and Development (CARD) grant by the Minnesota Department of Commerce to produce a white paper with recommendations on updates to Minnesota's energy efficiency cost-effectiveness framework. The objective of this project was to describe how the key elements of the National Standard Practice Manual (NSPM) could be applied to energy efficiency cost-effectiveness analyses in Minnesota. To determine how the NSPM’s principles could be applied to Minnesota’s cost-effectiveness framework, Synapse examined Minnesota’s current energy efficiency screening policies and practices and interviewed stakeholders. We used the Resource Value Framework (RVF) described in the NSPM to recommend a Minnesota-specific test as the state's primary test.
Stakeholder Presentation - Updating the Energy Efficiency Cost-Effectiveness Framework in Minnesota
Synapse provided analysis and testimony on behalf of the South Carolina Coastal Conservation League and the Southern Alliance for Clean Energy on Duke Energy Progress' proposed updated value of solar calculations in their annual fuel cost docket. Witness Devi Glick submitted testimony (Docket no. 2018-1-E) regarding the appropriate calculation of benefit categories associated with the value of solar NEM calculations and compliance with the 2014 settlement agreement regarding distributed energy resources.
Surrebuttal Testimony of Devi Glick Regarding the Value of Distributed Energy Resources in Duke Energy's 2018 Annual Review of Fuel Costs
Synapse provided analysis and expert testimony on behalf of the South Carolina Coastal Conservation League and the Southern Alliance for Clean Energy for South Carolina Electric & Gas’ (SCE&G) 2018 annual update of solar PV avoided costs under PURPA. Witness Devi Glick submitted testimony (Docket no. 2018-2-E) regarding the appropriate calculation of benefit categories associated with the value of solar calculation for PURPA QF rates and for Act 236 compliance.
Surrebuttal Testimony of Devi Glick on SCEG Fuel Costs
Northeast Energy Efficiency Partnerships (NEEP) and Synapse conducted a regional assessment of the tools, resources, and data sources used and useful as the region embarks on plans to help meet carbon reduction goals via Strategic Electrification. The work was supported by the National Renewable Energy Laboratory (NREL).
On September 20, 2018, NEEP's Elizabeth Titus joined Synapse's Asa Hopkins and Kenji Takahashi to share the results of the survey and collect additional input on how to move strategic electrification forward in the region.
This webinar is part of Synapse’s Third Thursday webinar series. Watch the webinar on our YouTube channel.
Synapse conducted a study on the economic impacts of a statewide ban on fracking in Florida.
Report on the impacts of utility investment in developing competitive markets, particularly with respect to electric vehicle infrastructure.
Wild fires rage in California. Communities continue rebuilding after devastating storms. The next financial crisis could lurk around the next corner. Worst-case scenarios are happening, but the current public policy framework leaves communities defenseless against them.
On December 21, 2017, we celebrated the release of Worst-Case Economics: Extreme Events in Climate and Finance, the latest book by Frank Ackerman (Synapse Principal Economist). Dr. Ackerman joined Bruce Biewald for our Third Thursday webinar series to discuss his new book, which Juliet Schor described as "highly accessible but profound" and Samuel Bowles called "an important book and a delight to read."
Here's a brief description from Dr. Ackerman:
The stock market and the climate are well-behaved most of the time – but those are not the times we worry about. Worst-case scenarios are all too real and all too common. The financial crisis of 2008 was not the first or the last to destroy jobs, homeownership and savings for millions of people. Ever-weirder weather includes megastorms clobbering communities from New York to Bangladesh, rising sea levels, and heat waves killing thousands across Europe.
Climate and financial crises are serious events, requiring vigorous responses. Yet public policy is trapped in an obsolete framework with a simplistic focus on average or likely outcomes rather than on dangerous extremes. What would it take to create better analyses of extreme events in climate and finance, and an appropriate policy framework for worst-case risks? Worst-Case Economics offers accessible and surprising answers to these crucial questions.
Avoided Energy Supply Costs in New England 2018 study materials:
- AESC 2018 Report - October Re-Release
- AESC 2018 Report - June Re-Release
- AESC 2018 Report - March 30 Release
- Click here to download the User Interfaces.
- Appendices for the AESC 2018 Report and a slide deck with study results can be found below.
For more information about the AESC study, please visit our project page.
Synapse has also conducted supplemental analysis on the avoided costs of compliance of the Massachusetts Global Warming Solutions Act. Visit here for more details.
Appendix C - AESC 2018
Appendix D - AESC 2018
Appendix J - AESC 2018
AESC 2018 Presentation of Results
Pepco Holdings Inc. has proposed to build a new substation in the Mt. Vernon area in Washington, DC at a cost of over $150 million. Synapse analyzed the area to determine whether the proposed substation is required to maintain reliability. In the resulting report, Synapse demonstrates how non-wires alternatives such as energy efficiency, distributed generation, demand response, or storage could maintain reliability at a much lower cost.
Synapse Energy Economics joined with Sustainable Energy Advantage (SEA), as well as members from NECEC, Mass Energy Consumers Alliance, E4theFuture, and other organizations to analyze the current state of regional renewable portfolio standards in light of many of new policy actions that have been put into place over the last several years. These policy actions include new legislation requiring long-term contracting for renewables and other resources in Massachusetts, Connecticut, and Rhode Island, revised incentives for distributed generation resources, changes to RPS polices in other states in New England, proposed Massachusetts-specific CO2 caps, and newly-revised forecasts for electricity sales that take the full impact of new energy efficiency measures into account.
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. Based on its analysis of the 2017 proposal, Synapse recommended that the BGS process should not move away from procuring a fixed price product that was meant to protect ratepayers form market volatility to a product that slowly increases protection for bidders at ratepayers’ expense.
On behalf of Consumers for Sensible Energy and a number of other non-governmental organizations, Synapse analyzed the need for, and the cost of, the Access Northeast (ANE) natural gas pipeline. As proposed, the ANE pipeline relies on a new funding mechanism whereby electric ratepayers would pay for new gas pipelines. This unprecedented funding proposal has spurred controversy and litigation: the Massachusetts Supreme Judicial Court and the New Hampshire Public Utilities Commission both rejected this approach, declaring that it violates state laws enacted to restructure the electric utility sector and to protect consumers from undue financial risk. Pipeline proponents claim that the ANE pipeline is needed to relieve capacity constraints on New England’s natural gas pipeline system and that the cost of the pipeline is justified because it will ultimately save money for New England electric ratepayers.
Synapse’s analysis showed otherwise. Any savings created by the ANE pipeline are likely to be outweighed by its costs, which are more than twice what proponents have generally reported. The analysis also indicated that the need for natural gas in New England will decrease dramatically within a few years of ANE’s construction. This would alleviate the capacity constraints cited to justify the pipeline. Synapse modeled energy use, prices, and emissions in a base scenario in which there is no new pipeline compared to a scenario in which the ANE pipeline is constructed.
New England's Shrinking Need for Natural Gas
Synapse’s Rachel Wilson provided analysis and testimony on an Avista Corporation rate case before the Washington Utilities & Transportation Commission. Ms. Wilson evaluated Avista’s production cost modeling, which used the AuroraXMP model, to determine if its requested increase in power costs was reasonable. She found that Avista’s modeling methodology led to a sustained overestimate of annual power supply costs, as evidenced by the compounding of credit deferral balances in its Energy Recovery Mechanism. Ms. Wilson recommended that Avista recalibrate its modeling to allow the Energy Recovery Mechanism to function as intended—to capture the variability between modeled and actual power supply costs. She further recommended that Avista more fully explore the possibility of joining the Western Energy Imbalance Market, which is a real-time wholesale energy market in which participants can buy and sell energy when needed.
The Southwest Energy Efficiency Project (SWEEP) conducted a study on benefits of residential heat pumps for space heating and water heating in five major cities in the Southwest. Kenji Takahashi of Synapse Energy Economics played a key advisory role assisting SWEEP with conducting the first major analysis of heat pumps against natural gas heating in the region. More specifically, he reviewed, advised, and offered recommendations on key assumptions and methodologies for evaluating energy, economic, and emissions impacts of heat pumps.
You can read the report on SWEEP's website.
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 prepared a summary of best practices in utility demand response (DR) programs and then compared those practices with HydroQuebec Distribution's planned DR resource and programs in their 2017-2026 Supply Plan, resulting in a set of recommendations for programmatic activities and revised planning processes. Synapse produced an expert report as well as a presentation used during live testimony.
Best Practices in Utility Demand Response Programs (Testimony Slide Deck)
In February 2017, the utilities with ownership of Navajo Generating Station in Arizona voted to cease operations of the coal-fired power plant. Two months later, Peabody Energy, operator of the mine that supplies fuel to Navajo, presented an analysis before the Arizona Corporation Commission demonstrating that Navajo is economically viable. On behalf of Sierra Club, Synapse examined this study, which was commissioned by Peabody and conducted by Navigant. Synapse found that Navigant relied on overstated market energy prices and understated Navajo's fuel prices, resulting in nearly $2 billion in errors.
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 was engaged by Riverkeeper and the Natural Resources Defense Council (NRDC) to analyze replacement energy and capacity resources associated with the retirement of the Indian Point Energy Center (IPEC). Synapse utilized the National Renewable Energy Laboratory ReEDS modeling system to estimate an economically optimal expansion of renewable energy resources in New York that would (i) meet Clean Energy Standard (CES) requirements; (ii) achieve required energy and capacity requirements with IPEC retired so as to maintain reliability, and (iii) track the energy production and capacity expansion costs of meeting all New York State requirements during the period 2016 to 2030. Our analysis found that the most cost‐effective replacement resource scenario includes an increase in the level of energy efficiency procurement in New York State above and beyond assumed CES levels, towards the most aggressive, achievable energy efficiency levels that NYSERDA and New York utilities can achieve. Increased levels of energy efficiency investment—and clear direction from the Public Service Commission to ensure those levels in fact materialize—will reduce the cost of achieving the CES’s 50 percent by 2030 renewable energy requirement.
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 analyzed the impacts of increasing the Connecticut Renewable Portfolio Standard.
Synapse launched a report in the fall of 2018 examining the technology options and impacts for building decarbonization in California, with a primary focus on air source heat pumps for space and water heating. The report examines electric grid impacts as well as the impact on customer economics. This included a detailed comparison of customer economics under different existing and near future rate structures. The report concludes with a set of recommended actions, including policy changes, to accelerate market transformation in the building sector.
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.
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
Synapse was retained by Earthjustice to draft a whitepaper discussing grid resiliency issues in the context of the United States Department of Energy (DOE)’s “grid resiliency pricing rule” proposal. DOE’s proposal directed the Federal Energy Regulatory Commission (FERC) to design rules that would guarantee full recovery of costs for all generating units operating in competitive wholesale markets with 90 days of fuel supply on-site (conventionally understood to refer to nuclear and coal-fired units). Synapse’s whitepaper discusses several key problems associated with this proposal: first, the authorities in charge of the nation’s wholesale energy markets (including FERC itself as well as ISO/RTOs and state agencies) have devoted substantial efforts to increasing the reliability and resiliency of the grid system and have reasonable, market-based approaches for accomplishing this goal. Second, fuel supply disruptions have not historically been a significant cause of service interruptions. Third, coal units in particular are vulnerable to both fuel supply disruptions and other failures during extreme weather and temperature events, and have demonstrated decreasing reliability over time. Synapse’s whitepaper was filed under FERC docket RM18-1-000 in support of comments submitted by Earthjustice, Environmental Defense Fund (EDF), Natural Resources Defense Council (NRDC), Sierra Club, Sustainable FERC Project, the Union of Concerned Scientists (UCS), the Center for Biological Diversity, the Environmental Law and Policy Center, the Southern Environmental Law Center (SELC), Conservation Law Foundation (CLF), Environmental Working Group, and Fresh Energy.
A coalition of organizations including Michigan Environmental Council, Sierra Club, and NRDC, hired Synapse to review and provide expert testimony regarding DTE Electric's application for a Certificate of Necessity to construct a 1,100 MW Natural Gas Combined Cycle plant. Synapse experts Avi Allison and Bob Fagan filed testimony critiquing DTE's assumptions regarding renewable and market resource alternatives to its proposed gas plant, and demonstrating that DTE would likely save its customers money by investing in a combination of energy efficiency, renewable energy, and market purchases rather than building a new gas plant.
Direct testimony analyzing overall need and critiquing a DTE Energy proposed natural-gas fired combined cycle plant in Michigan
Rebuttal testimony analyzing overall need and critiquing a DTE Energy proposed natural-gas fired combined cycle plant in Michigan
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.
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