Synapse provided expert assistance to Sierra Club related to Cleco Power LLC’s application before the Louisiana Public Service Commission seeking authorization to install pollution control equipment for compliance with MATS on three coal-fired units in Louisiana (Dolet Hills, Rodemacher 2, and Madison 3). Synapse testified that the Company's modeling supporting the application contained numerous deficiencies, including an assumption of the overprocurement of replacement capacity, a failure to evaluate the opportunity for market purchases and sales, and a lack of consideration for any one of several impending environmental regulations.
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Cross Answering Testimony of Jeremy Fisher Regarding Cleco Power Request for Authorization to Retrofit Coal Plants
As a subcontractor to Eastern Research Group, Synapse provided consultation services to the U.S. EPA in which we reviewed and assessed numerous energy efficiency programs across the United States on a variety of topics including, but not limited to: (a) costs of saved energy; (b) energy savings at the sector and portfolio levels; (c) annual savings ramp-up rates; (d) energy efficiency measure life; (e) energy savings decay profiles; (f) participant costs vs. program incentive; (g) energy efficiency potential; and (h) energy efficiency portfolio standards.
Together with subcontractor Nancy Brockway, Synapse assisted the Ontario Energy Board in developing options for the design and implementation of a ratepayer‐funded, long‐term rate assistance program for low‐income electricity consumers.
Sierra Club retained Synapse to perform a technical and economic review of planning studies and analysis made by the Omaha Public Power District (OPPD) and its subcontractors. Synapse performed an integrated resource plan analysis to assist Sierra Club in this matter.
In 2012, PSE&G petitioned the New Jersey Board of Public Utilities to extend its existing capital infrastructure program by expanding the program with 22 new projects. The Company proposed to spend $195 million through 2012 in the projects associated with this petition. On behalf of the New Jersey Division of Rate Counsel, Synapse performed a technical and engineering assessment of the reliability of the PSE&G electric distribution system and reviewed the prudency of the proposed infrastructure projects.
Synapse assisted the Howard County Council (HCC) in its investigation into the reliability of electric power supply for certain areas in Howard County, Maryland. This investigation occurred in two phases: Phase I examined the 14 feeders identified by the original petitioners of the case, and Phase II examined the 33 additional feeders identified by HCC. Based in part on Synapse's comments and testimony, the electric utility modified its designation of poorest performing feeders to include outage duration metrics.
On November 27, 2013, Rockland Electric Company (RECO) petitioned the New Jersey Board of Public Utilities for approval of an increase in its operating revenues of approximately $19.3 million (BPU Docket No. ER13111135). Synapse assisted the New Jersey Division of the Rate Counsel in reviewing distribution spending and reliability matters in the rate case. Project completed July 2014.
The Rockland Electric Company (RECO) petitioned the New Jersey Board of Public Utilities for approval of $1.35 million over the course of three years for implementing a Low Income Audit and Direct Install Energy Efficiency II Program. Synapse assessed the reasonableness of the proposed program designs, including incentive structures; key program assumptions, including measure costs and savings per participant; program budget; and participation in the Low Income Audit Program.
Synapse assisted Sierra Club in reviewing and critiquing Southwestern Public Service Company’s application for a rate increase to cover, among other things, capital investments at two of its coal-burning power plants (Harrington Station and Tolk Station) in the Texas panhandle. The case was settled.
For this project, Synapse supported RAP with regional discussions of key energy efficiency issues—including decoupling and other mechanisms for recovering the lost base revenues from energy efficiency—for the State and Local Energy Efficiency Action Network (SEE Action). The project included a Regulatory Policy Exercise, where Tim Woolf and other participants prepared mock testimony and were subject to cross-examination in a mock hearing before commissioners, commission staff, and consumer advocates in the Midwest. Mr. Woolf’s mock testimony argued for the implementation of decoupling to support energy efficiency and other demand resources.
Synapse assisted its non-governmental clients in providing comments on the Clean Power Plan, the EPA’s proposed guidelines for reducing carbon dioxide emissions from existing fossil fuel-fired power plants by 30 percent below 2005 levels by 2030. Synapse analyzed state-specific considerations for compliance for the following states: Alabama, Arizona, Florida, Georgia, Illinois, Louisiana, Louisiana (CLECO), Minnesota, Montana, Nevada, North Carolina, North Dakota, Oregon, South Carolina, South Dakota, Tennessee, Utah, and Virginia.
Calculating Georgia 111(d) Target
Alternate Scenarios for 111(d) Implementation in North Carolina
Industrial Energy Efficiency and Combined Heat and Power (CHP) represent proven, effective, and underutilized near-term energy options to help the United States enhance energy efficiency, improve environmental quality, promote economic growth, and maintain a robust energy infrastructure. A key to achieving additional use of Industrial Energy Efficiency and CHP is successful implementation of supportive state policies. For this project, Synapse worked with the Regulatory Assistance Project to help DOE facilitate regional working group meetings focused on Industrial Energy Efficiency and CHP deployment. Project completed June 2014.
The New York Public Service Commission has undertaken an ambitious initiative to improve system efficiency, empower customer choice, and encourage greater penetration of clean generation and efficiency technologies. Called the Reforming the Energy Vision initiative, or REV, this case is proceeding on two tracks. The focus of Track One is one the role of utilities in promoting distributed energy resources. On behalf of the Natural Resources Defense Council (NRDC), Synapse reviewed the Commission’s initial framing document for Track One and provided comments on the role of distribution service providers (DSP) in preserving energy efficiency, distributed generation, and demand response programs. Synapse also reviewed potential DSP interactions with NY ISO and the need to provide consistent treatment of value streams between retail programs and wholesale markets.
Synapse is currently assisting NRDC with Track Two issues.
Reply Comments to New York Department of Service Staff Straw Proposal on NY REV Track One Issues
In collaboration with the Black Mesa Water Project, a Navajo environmental justice organization, Synapse analyzed alternatives to the coal-fired Navajo Generating Station and the Kayenta coal mine that supplies it with fuel. Using the IMPLAN and NREL JEDI economic impact models, the project team assessed the economic impacts of closing one NGS unit, cutting back the Kayenta mine by one-third, and replacing these resources with renewable alternatives. The team also analyzed the hidden costs of operating NGS, such as environmental controls and health impacts. Results showed that building and operating 900 MW of renewable energy (a mix of wind and solar projects) could replace the jobs and incomes offered by existing energy projects with more secure, longer-term employment and development while reducing the harm to health in communities surrounding NGS and Kayenta.
Now updated to include the Clean Power Plan and other relevant regulations, the Synapse CO2 price forecasts reflect a reasonable range of expectations regarding future efforts to limit greenhouse gas emissions. Prudent planning requires that utilities and stakeholders take this cost into account when engaging in resource planning. Our forecast, updated annually, includes low, mid, and high case projections for CO2 prices out to 2040 based on thorough analysis of proposed federal regulatory measures, ongoing state and regional policies, the price of CO2 already being factored into federal rulemakings, recent CO2 price forecasts from utility IRPs, and policy analysis and modeling from the research community.
2015 Carbon Dioxide Price Forecast
CO2 Price Report, Spring 2014: Includes 2013 CO2 Price Forecast
2013 Carbon Dioxide Price Forecast
2012 Carbon Dioxide Price Forecast
Synapse provided the Southern Environmental Law Center with technical consulting services to support its intervention—on behalf of the Coastal Conservation League (CCL) and the Southern Alliance for Clean Energy—in the solar net metering docket commenced by the South Carolina Public Service Commission (PSC). Synapse provided the technical analyses that SELC presented within this proceeding. These included qualitative and quantitative analysis and evaluation of resource valuation methodologies and NEM-related rate designs proposed by other parties to the docket, and development of alternative resource valuation methodologies and NEM-related rate designs.
On behalf of the Northeast Energy Efficiency Partnerships, Synapse prepared a guidance document for utility regulators on several key principles of energy efficiency cost-effectiveness screening. The key issues addressed in the study include: the alignment of efficiency screening with energy policy goals; accounting for non-energy impacts; choosing the appropriate discount rate; and accounting for environmental compliance costs. The guidance document was adopted by the NEEP Regional Evaluation, Measurement and Verification Forum.
Bruce Biewald and Sarah Jackson presented on issues related to the EPA's proposed Clean Power Plan at the Technical Summit on EPA's Carbon Pollution Standards for Southeast Advocates in Atlanta, Georgia on August 13-14, 2014. The summit was convened by the Southeast Climate & Energy Network. Mr. Biewald and Ms. Jackson presented on the fundamentals of the rule and tools for compliance, including spreadsheet tools, EPA's AVERT, utility system models, and regional and national electric system models.
Tools for 111(d) Compliance Planning
Overview of the Clean Power Plan for 2015 Summit of Southeast Advocates
Bruce Biewald presented “The Future of Coal: Economics and Planning” at the Harvard Graduate School of Arts and Sciences course Energy 101 on January 21, 2014. Topics covered include the economics of coal versus natural gas; the role of energy efficiency; reliability concerns; the need for prudent planning; and ratemaking practices.
The Office of the People's Counsel (OPC) retained Synapse and Nancy Brockway to develop and present recommendations regarding the implementation of time-varying rates, including time-of-use pricing and critical peak pricing, in the District of Columbia. The Synapse project team advised the OPC regarding rate design principles and options, the methodology for determining peak periods and prices, and appropriate customer protections.
Bruce Biewald presented "Transitions to a 21st Century Generation System" at the EUCI Annual Hawaii Power Summit on December 3, 2014. Mr. Biewald presented as part of a panel discussing the impacts of Hawaii's recent efforts to re-tool its power system through multiple major study and planning efforts.
Bruce Biewald presented “Understanding the 111(d) Rule” at the Midwestern Carbon Rule Advocates Technical Meeting in Chicago, Illinois on July 24, 2014.
Synapse was asked by the New Hampshire office of the Conservation Law Foundation to update our July 2011 financial analysis of the two coal-fired units at PSNH's Schiller Station. Synapse performed the analysis quickly using our newly developed Coal Asset Valuation Tool (CAVT). Project completed March 2014.
Synapse assisted the Sierra Club in evaluating the future economic viability of a group of Edison Mission Energy coal plants that were subsequently purchased by NRG. Synapse used its own CAVT tool to compare the forward‐going costs of the fleet against projected PJM market revenues.
On June 10, 2014, the Maine Public Utilities Commission issued a Notice of Inquiry (NOI) into the design and implementation of a methodology to determine the value of distributed solar energy in the state of Maine. To inform the inquiry, which served as the first step in designing a study mandated by legislation to support solar energy development in Maine (P.L. 2013 CH. 562), the Commission asked interested parties to respond to questions detailed in the NOI. Synapse assisted the Maine Office of the Public Advocate (OPA) in responding to the inquiry, and later in developing comments on the subsequent draft value of solar methodology issued by the PUC on October 30, 2014.
The OPA’s comments on the draft methodology include recommendations on assumptions about fuel price escalation and heat rate, and suggested modifications to the technical and economic analysis that would more closely align the methodology with best practices.
Comments of the Office of the Public Advocate on the Notice of Inquiry into the Determination of the Value of Distributed Solar Energy Generation in Maine
Synapse authored a white paper regarding energy efficiency policies in Virginia, with a focus on cost-effectiveness screening, rate impacts, and performance incentives.
Appropriately valuing the cost of carbon dioxide (CO2) emissions to society is critical to good long-term decision-making in the energy industry and other key economic sectors. The social cost of carbon (SCC) developed by the US Interagency Working Group and used to evaluate the climate benefits of rulemaking by various federal agencies is calculated using flawed methodology, and likely underestimates the true cost of climate damages. In an op-ed for EPS Quarterly, Synapse staff discuss the limitations of the methodology used by the Working Group and why it is important that the figure is calibrated to our best, most up-to-date scientific understanding of our climate crisis. "What Carbon Costs Us" was published in the December 2014 issue of EPS Quarterly.
Rick Hornby presented “Wholesale Capacity and Energy Price Suppression Benefits of Efficiency and Distributed Generation” at the NESEA Building Energy 14 Conference on March 6, 2014. The presentation explained how retail customers who invest in distributed generation and/or energy efficiency reduce the quantity of wholesale/conventional utility electric capacity and energy that utilities or merchant suppliers acquire to supply them, and how those reductions benefit all retail customers by suppressing the prices of the wholesale/conventional utility capacity and energy that all retail customers ultimately pay.
Synapse provided technical consulting services to support the Alliance for Solar Choice (TASC) in its involvement in a proceeding regarding the WE Energies (WEPCO/WGC) Electric, Natural Gas, and Steam Rate Change Request before the Public Service Commission of Wisconsin (Docket No. 5‐UR‐107). Synapse analyzed WE Energies' proposal to replace its nine existing customer generation service tariffs with four new customer-owned generation (or distributed generation) service tariffs. Synapse developed discovery and sponsored direct and surrebuttal testimony to support TASC in the proceeding.
Surrebuttal Testimony of Rick Hornby Regarding Wisconsin Electric Power Company Rate Case
Synapse, along with the Regulatory Assistance Project, managed a working group of experts from different perspectives from around the U.S. to recommend a common framework for evaluating the cost-effectiveness of demand response resources. The report finds that the framework typically used to evaluate energy efficiency—with five tests addressing different perspectives—is most commonly used for evaluating demand response resources. The report then describes how some of the costs and benefits of demand response resources are different from those of energy efficiency resources, and thus require different evaluation techniques. This is particularly true for estimating avoided capacity costs.
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