Nebraska Public Power District (NPPD) invited independent reviews of its recent planning exercises, including its 2012 Generation Options Analysis (GOA) and its February 2013 NPPD Draft Integrated Resource Plan (Draft IRP). Sierra Club retained Synapse to review NPPD’s Draft IRP and to provide expert comments on this iteration of the planning process.
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Synapse assisted NEEP and EPA to develop information regarding how energy efficiency (EE) is used in system planning studies in the Northeast. Synapse reviewed current practices by PJM, NY ISO, and ISO-NE and compared their treatment of EE in system planning with recommendations by EPA and the Lawrence Berkley National Laboratory (LBNL). After review of the information by EPA, Synapse helped prepare and participate in meetings with key stakeholders on how EE can be used in developing state implementation plans (SIPs) to comply with EPA regulations. After the meetings, Synapse participated in a regional forum open to all stakeholders on the use of EE forecasts for system planning and SIPs.
Thomas Vitolo presented "Net Metering and Mississippi" at the 13th Annual Southern BioProducts and Renewable Energy Conference in Hattiesburg, Mississippi on November 13, 2014.
Synapse provided expert advice on and analysis of energy efficiency and CHP 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’ monthly performance, designs and budgets, avoided energy supply cost estimates, cost-benefit analyses, energy savings protocols, EM&V studies, and overall administrative structure. We also periodically reviewed and commented on New Jersey Energy Master Plans, and on a three-year energy efficiency program plan called the Comprehensive Resource Analyses.
Synapse helped the New Jersey Division of Rate Counsel analyze the request by New Jersey Natural Gas Company and South Jersey Gas Company to continue their respective Conservation Incentive Programs, under which they are allowed to retain a portion of the gas supply capacity savings avoided as a result of reductions in customer usage due to the utilities' efficiency programs. Project completed June 2014.
The New Jersey Division of Rate Counsel retained Synapse to determine the reasonableness of New Jersey Natural Gas Company's proposed negotiated rates and terms for gas transportation and balancing services to the Red Oak generating facility. Project completed January 2014.
Synapse provided technical support and expert modeling to the Nova Scotia Utility and Review Board (NS UARB) during the course of the 2014 Integrated Resource Plan (IRP) development by Nova Scotia Power. In collaboration with Nova Scotia Power and the staff and other consultants of the NS UARB, Synapse helped to develop an analysis plan, critiqued Strategist model input assumptions, provided alternative assumptions, conducted modeling of alternative Candidate Resource Plans, and filed detailed comments with the NS UARB on NSP’s final 2014 IRP. Synapse’s work contributed towards development of an approved long-term IRP that contained a “mid-level” investment by NSP into demand-side management (DSM) resources.
Filing to the Nova Scotia Utility and Review Board on Nova Scotia Powers October 15, 2014 Integrated Resource Plan: Key Planning Observations and Action Plan Elements
Synapse provided expert services in a PacifiCorp multi-state IRP development stakeholder process on behalf of the Sierra Club. As part of this project, Synapse reviewed the PacifiCorp 2013 IRP and all supporting workpapers; reviewed stakeholder materials provided in the PacifiCorp 2013 IRP development; reviewed new emerging regulations and proposed regulatory guidelines for consistency with IRP assumptions; issued discovery to the Company to elicit details, assumptions, and modeling files; and participated in stakeholder calls. Synapse submitted comments on PacifiCorp’s IRP in Oregon and Washington.
Sierra Club Preliminary Comments on Pacificorp 2013 Integrated Resource Plan in Washington Docket UE-120416
Synapse provided expert testimony for a PacifiCorp general rate case regarding the prudence of environmental retrofits undertaken in the 2012-2013 timeframe. Synapse filed direct testimony in Utah and Wyoming and attended hearings in Utah. The case in Wyoming was settled.
Direct Testimony of Jeremy Fisher in the Matter of the Application of Rocky Mountain Power for Authority to Increase its Retail Rates in Utah
Synapse reviewed the rate design and cost recovery aspects of PEPCO's Dynamic Pricing proposal for residential customers in the District of Columbia. Project completed June 2014.
Atlantic City Electric petitioned the New Jersey Board of Public Utilities to request an increase of $61.65 million ($65.95 million including Sales and Use Tax) in distribution rates. This would result in a monthly bill increase of $9.57 or 5.62% (for a customer using 1,000 kWh/month). Synapse assisted the New Jersey Division of Rate Counsel by performing a technical and engineering assessment of the costs associated with the Company’s petition, a prudency review of costs and benefits associated with the Company’s petition, and a review of the Company’s reliability performance.
Synapse is conducting PLEXOS production cost modeling and examining California investor-owned utility (CA IOU) filings pertaining to various rate design considerations in California. In particular, Synapse is examining patterns of marginal costs for CA IOUs, assessing greenhouse gas emissions under different time-of-use (TOU) pricing periods, and reviewing proposed TOU periods that may reflect the changing shape of California’s “net load” curves due to the presence of increasing amounts of renewable resources, especially solar.
Reply Testimony of Bob Fagan and Patrick Luckow Regarding the Relationship between California Investor Owned Utilities Hourly Load Profiles under a Time-of-Use Pricing and GHG Emissions in the WECC Regions
Testimony on Pacific Gas and Electric’s Marginal Energy Costs and LOLE Allocation Among TOU Periods
Bruce Biewald presented "Protecting Consumers from Bad Utility Planning" at the Electricity Consumers Resource Council Fall Workshop in Washington, DC on October 21, 2014. Mr. Biewald provided examples of poor utility planning and discussed what should be done by utilities, regulators, and consumer and environmental advocates to improve planning practices.
Synapse provided consulting services to the New Jersey Division of Rate Counsel regarding the petition filed by the Public Service Electric and Gas Company (PSEG) requesting that the storm costs incurred in 2011 and 2012 be considered reasonable and prudent. Synapse analyzed the petition, prepared and reviewed discovery questions, and assisted in hearing participation. The Synapse work focused on a technical and engineering assessment, as well as a prudency review, of the costs associated with the Company’s response to five major storm events.
On behalf of the New Jersey Division of the Rate Counsel, Synapse analyzed, reviewed, and issued discovery requests regarding the energy efficiency and demand response components of the Public Service Electric and Gas (PSE&G) filing to adjust its Green Programs Recovery Charges. Key issues included program performance and cost effectiveness. Project completed in February 2014.
The Conservation Law Foundation (CLF) retained Synapse to provide expert witness services in a docket related to the prudence of Public Service of New Hampshire’s (PSNH’s) scrubber project at Merrimack Station (NH PUC Order N. 25,546). Synapse analyzed and presented testimony on issues related to whether or not Merrimack’s scrubber project was prudent, used, and useful in the context of contemporaneous market and regulatory conditions.
Synapse assisted the Vermont Public Service Department in evaluating the rate and bill impacts of the 2014-2034 Vermont Energy Efficiency Plan. Our analysis included rate, bill and participation estimates, both for historical impacts from the past ten years and future impacts for the next 20 years. The analysis included an innovative "bottom up" approach that more accurately captures the impact on rates from efficiency programs. Cost-effective energy efficiency resources will typically result in lower bills but higher rates. Synapse’s analysis investigated the magnitude of the higher rates relative to the lower bills for each customer sector (residential, business non-demand, and business demand customers), as well as for different types of customers (participants, non-participants, and customers on average).
The Board cited Synapse's report extensively in its Order in the 2013-2014 Demand Resources Plan Proceeding, and adopted Synapse's recommendation that the Energy Efficiency Utilities (“EEUs”) collect and report better data on customer participation, which is a key component in understanding the implications of rate and bill impacts.
The Maine Office of the Public Advocate (OPA) hired Synapse to assist in reviewing the 2014 Alternative Rate Plan proposed by Central Maine Power (CMP). As part of this review, Synapse assessed the reasonableness of CMP’s initial capital investment mechanism and advised the OPA on its Motion to Dismiss. Synapse evaluated CMP’s revised proposal for recovering capital investment costs and the degree to which the proposal fails to achieve the goals of performance-based ratemaking. Synapse also conducted an in-depth review of the Company’s revenue decoupling proposal. In addition to technical support on specific topics, Synapse developed policy-level testimony to synthesize the findings on all of the issues addressed by OPA to provide overall policy recommendations. Synapse provided support during the settlement process, and Tim Woolf testified at the hearings.
Surrebuttal Testimony Regarding Central Maine Powers Request for an Alternative Rate Plan
Synapse assisted Sierra Club with a brief review of the CLECO energy efficiency plans, including comments on the program budgets and savings goals.
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.
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
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