On behalf of the Sierra Club, Synapse prepared expert testimony in a docket before the Colorado Public Service Commission on the cost-effectiveness of energy efficiency programs. The testimony focused on the appropriate use of the total resource cost test, the need to include non-energy benefits, the need to properly account for environmental compliance costs, and the best way to address concerns about rate impacts and customer equity. Project completed June 2014.
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Surrebuttal Testimony Regarding the Public Service Company of Colorado Proposed Energy Savings Goals
For over 25 years, utility-funded energy efficiency programs have proven to be a widely available resource for meeting customer demand at low cost. We now have a wealth of experience demonstrating that energy efficiency programs cost a fraction of the cost of generating, transmitting and distributing electricity, and provide a variety of benefits in terms of lower bills, reduced system risk, increased system reliability, reduced environmental impacts and more. In June 2014, when the U.S. Environmental Protection Agency (EPA) issued proposed regulations under the Clean Air Act (CAA) for reducing greenhouse gas emissions from existing sources in the electricity industry, it created another compelling reason for states to promote energy efficiency programs.
Efficiency programs are among the lowest-cost options for reducing carbon emissions, and can play a significant role in reducing the costs of complying with the EPA’s new plan. However, if we are to unleash the full potential of energy efficiency programs to comply with CAA 111(d), many states will need to improve their procedures for reviewing and approving utility-funded programs. Enormous reservoirs of low-cost efficiency resources remain untapped, primarily because several regulatory practices and conventions hinder the identification and development of the full potential of energy efficiency resources. In an article for Public Utilities Fortnightly, Tim Woolf, Erin Malone, and coauthors describe two of the most important of these barriers and propose strategies for addressing them.
Synapse authored a paper discussing and comparing the amount of energy efficiency bid into U.S. capacity markets (New England’s FCM and PJM’s RPM) over the past several years.
Synapse assisted the National Home Performance Council with a broad campaign to improve the way that energy efficiency resources are screened and approved by commissions. The objectives of the campaign included addressing the current problems with energy efficiency screening practices, developing a new screening framework, and promoting a broader view of the benefits of energy efficiency. The campaign included extensive stakeholder discussions, as well as outreach to key decision-makers. The campaign is national in nature and focuses on several key states.
Recommendations for Reforming Efficiency Cost-Effectiveness Screening in the US: A presentation at the National Association of Regulatory Commissioners Annual Meeting
The Resource Value Framework: Reforming Energy Efficiency Cost-Effectiveness Screening
Synapse developed a whitepaper outlining the benefits of a regional energy imbalance market (EIM), including annual dollar savings and reliability improvements. Synapse examined the proposed integration of PacifiCorp (October 2014) and Nevada Energy (October 2015) into the CAISO EIM. The paper also discusses the ways in which all utilities (IOUs, municipals, and co-ops) would benefit from a regional EIM.
Synapse collected utility Integrated Resource Plans from nearly 200 entities in order to find as many CO2 price forecasts as possible. With this research in hand, Synapse CEO Bruce Biewald testified at a House Energy and Power Subcommittee hearing on the practice of estimating a future CO2 price in electric utility planning.
Synapse provided in-depth comments on the Duke Indiana Integrated Resource Plan (IRP) process, following stakeholder meetings and presentations by the utility. Synapse evaluated commodity prices, scenarios, alternatives considered, future environmental compliance obligations, and the economics of the utility's existing coal units. The final report was published February 2014.
The Nova Scotia Utility and Review Board retained Synapse to review the operation of Nova Scotia Power Inc.'s (NSPI) load retention rate (LRT) to ensure that NSPI is recovering its incremental production costs plus a contribution to fixed costs. Synapse reviewed the generation planning and scheduling assumptions and algorithms NSPI used to develop the week-ahead, day -ahead and hour-ahead forecasts of cost quantity (CQ) pairs it offers under this rate. The Synapse February 2014 audit concluded that the CQ-pair methodology originally used by NSPI did not produce a sufficiently accurate estimate of the incremental energy costs to bill PHP, and proposed that NSPI use a “differential method” instead.
After reviewing the Synapse February 2014 audit report and the comments on that report filed by interested parties, the Board issued a Decision Letter dated May 23, 2014 directing that Synapse be engaged to proceed with a supplementary audit of the newly implemented differential method of calculating costs of supplying PHP under the LRT. Synapse worked with NSPI to refine the differential method and released a supplementary report in September 2014.
Supplementary Audit of Port Hawkesbury Paper Load Retention Tariff
Synapse provided expert services to Sierra Club related to Indiana Michigan Power Company’s application for a Certificate for Public Convenience and Necessity (CPCN) for an SCR at Rockport 1. Synapse conducted thorough analysis of Company workpapers and identified key issues to the client.
Public Service Electric and Gas Company has petitioned the New Jersey Board of Public Utilities to approve the first five years of the $3.94 billion, ten-year Energy Strong program to harden utility infrastructure and guard against increasingly extreme weather. On behalf of the New Jersey Division of Rate Counsel, Synapse performed a technical and engineering assessment of the Energy Strong program as well as a comparative examination of the proposed program with PSE&G's Capital Infrastructure Program. In addition to this analysis, Synapse prepared and reviewed discovery questions and responses to discovery, assisted in the development of the Rate Counsel's policy position regarding the Energy Strong proposal, assisted in preparing comments and pre-filed direct testimony, and attended Board hearings. Synapse also filed direct and supplemental testimony, and provided cross-examination and live surrebuttal testimony. Project completed May 2014.
Synapse assisted the Sierra Club with reviewing Vectren South's request for Certificate of Public Convenience and Necessity (CPCN) at four coal-fired units in Indiana (Culley 2 & 3, and EW Brown 1 & 2). To evaluate the investments, Synapse reviewed Company workpapers and reconstructed an extended analysis of the short economic evaluation conducted by the Company, and proposed alternative mechanisms of valuation, as well as additional risks not considered by Vectren in the retrofit. Synapse provided expert testimony before the Indiana Utility Regulatory Commission.
Kenji Takahashi presented "Expected U.S. Climate and Environmental Policy: The Future of Coal Power and Clean Energy" at the Citizen's Alliance for Saving the Atmosphere and the Earth (CASA) seminar in Osaka, Japan on July 10, 2014. Presentation in Japanese.
Synapse assisted the Regulatory Assistance Project in an initiative to coordinate the activities and campaigns of environmental and consumer advocates. Topics addressed included protection of low-income customers, promotion of energy efficiency, promotion of renewable resources, and addressing climate change. Project completed May 2014.
Synapse presented testimony on behalf of the Pennsylvania Office of Consumer Advocate on whether the request by the Pennsylvania utilities of First Energy to accelerate the deployment schedule for their smart meters was reasonable (Docket No. M-2013-2341990 et al). Project completed June 2014.
Synapse assisted the Cambridge Energy Alliance with various aspects of its participation in the New England Forward Capacity Market (FCM). Project completed July 2014.
Synapse provided consulting and strategic services to support Efficiency Maine's participation in the Forward Capacity Market.
In the rush to interpret EPA’s draft 111(d) rule for limiting CO2 emissions at existing power plants, a number of sources mischaracterized or misunderstood key elements and implications. In a webinar delivered June 19, 2014, Synapse clarified the fundamental components of 111(d), discussed implications for individual states, and answered questions from participants.
In collaboration with partners from Harvard University, the University of Delaware, and Boston University, Synapse modeled the climate, air quality, and health benefits of offshore wind facilities in the Mid-Atlantic United States. The study simulated benefits of offshore wind facilities of different sizes in two locations that are in early stages of planning and development. The results demonstrated that these offshore facilities can produce health and climate benefits of between $54 and $120 per MWh of generation. The project was a joint effort of Synapse, the Center for Health and the Global Environment at the Harvard T.H. Chan School of Public Health, the University of Delaware College of Earth, Ocean & Environment, and the Boston University School of Public Health Department of Environmental Health. Environmental Research Letters published the findings in its July 2016 volume.
Bruce Biewald presented “How the Electric Grid Works: Dispatch, Planning, and Regulation” as a guest lecturer at the MIT Course “Electricity, Economics, and the Environment” on February 13, 2014.
Synapse was hired by the Idaho Conservation League to collect information on the sources of Idaho's existing electricity supply and the potential for efficiency and renewables in the state. The League was interested in understanding the current fuel mix of the generation serving Idaho and the amount of this electricity that is generated out of state. Synapse pulled information from the IRPs of the three Idaho IOUs and other sources to characterize the state's current electricity fuels. Synapse also presented information on renewable energy potentials in Idaho and reviewed the assumptions about efficiency and renewables in the utilities' IRPs, identifying areas where these assumptions were not consistent with the literature. Project completed February 2014.
Synapse provided testimony on behalf of Citizens Action Coalition of Indiana regarding Indianapolis Power and Light's (IPL) application for the construction of a new natural gas combined-cycle plant. Synapse found that the Company had likely overestimated future capacity prices and relied on flawed modeling methodology to determine the project's need (among other issues).
Testimony of Jeremy Fisher Regarding Indianapolis Power & Light Company Petition to Replace Retiring Thermal Generators with a Combined Cycle Generation Turbine
Synapse provided expert services to the Sierra Club related to Louisville Gas & Electric Company and Kentucky Utilities’ (the Companies) joint application to continue and amend their demand-side management (DSM) programs and implement a revised DSM tariff (Kentucky PSC Case No. 2014-00003). Working with Sierra Club attorneys, Synapse reviewed and drafted testimony on the Companies’ proposed DSM Plan, discovery responses, and supporting documentation, including an energy efficiency potential study and historical review of the Companies’ DSM programs. Synapse’s testimony documented, among other concerns, that the Companies had not considered the opportunities available from industrial DSM programs, despite an interest among their industrial customers for such programs, and were therefore likely missing opportunities to achieve a significant amount of cost-effective savings. As a result of this testimony, the Commission found in its November 14 order that the Companies should commission a study that examines the potential benefits of industrial DSM programs.
Synapse provided expert services for Sierra Club and Earthjustice in reviewing Lousiville Gas and Electric and Kentucky Utilities' filing for a proposed new 700 MW natural gas combined-cycle (NGCC) plant. The Company later withdrew the application for the new construction due to loss of load.
The Midwest Renewable Energy Tracking System (M-RETS) tracks information about renewable energy production and delivery in participating states and provinces (Illinois, Indiana, Iowa, Manitoba, Minnesota, Montana, North Dakota, Ohio, South Dakota, and Wisconsin). For this project, Synapse created a model to explore alternatives to the Midwest Renewable Energy Tracking System’s (M-RETS) previous fee structure, benchmarked model forecasts to actual data, and created a matrix of Renewable Portfolio Standards tariffs in the M-RETS region.
Following the devastating impact from Superstorm Sandy, Public Service Electric and Gas Company introduced a 10-year, $3.9 billion investment program for grid hardening and grid resiliency. The company’s petition sought $2.6 billion in rate recovery over five years. Almost 18 months after the initial petition, the Company reached a settlement with intervening parties for $1.2 billion over three years. In the whitepaper “Making the Grid More Resilient within Reason,” Synapse identified themes and lessons from our involvement in the case on behalf of New Jersey Rate Counsel for consumer advocates to ensure that utilities develop reasonable and prudent programs to plan for major outage events. These themes include: understanding proper goals, understanding cost-effectiveness analysis, ensuring proper planning, and preventing gold-plating.
Synapse and its subcontractor, Nancy Brockway, assisted the Massachusetts Department of Energy Resources (DOER) in docket DPU 14-04, an investigation into Time Varying Rates (TVR). Time-varying rate structures can provide valuable signals to customers regarding the costs of service at different times of the day, week, and year. These signals can help to reduce demand during expensive peak periods, thereby reducing electricity costs. In assisting the DOER prepare comments, Synapse evaluated whether TVR should be offered for basic service, and offered recommendations for developing a menu of rate design options that could be expanded over time. Synapse also analyzed the experience in other jurisdictions with opt-out versus opt-in TVR structures, and recommended the adoption of certain customer protection measures. Finally, Synapse assessed the merits of adopting peak-time rebate programs in Massachusetts.
Synapse assisted the Mississippi Public Service Commission (PSC) in Docket No. 2011-AD-2, a proceeding opened to develop and implement net metering and implementation standards for Mississippi. Synapse conducted a comprehensive cost-benefit analysis for net metering and interconnection in Mississippi, to help the PSC make an informed decision regarding the costs and benefits and assist it in developing appropriate policies for the state. Synapse assessed both the direct and indirect costs and benefits of net metering and interconnection—whether under a net metering and interconnection or alternative policy scenario—and considered and quantified both energy-related and non-energy costs and benefits. Based on the findings of the Synapse report, the Commission found it is in the best interest of ratepayers to proceed with the development of proposed net metering and interconnection rules.
Synapse estimated the economic impacts of investment in wind, solar PV, and energy efficiency in Montana. The project team used the IMPLAN model to determine direct, indirect, and induced impacts in terms of jobs per million dollars of spending on construction and O&M for each resource. These results were then translated to jobs per average megawatt of energy produced over the next 20 years to allow for an apples-to-apples comparison across resources.
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.
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.
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