The West Virginia Consumer Advocate retained Synapse to determine if the proposed merger of Appalachian Power Company (APCo) and Wheeling Power Company (WPCo) would be beneficial for West Virginia ratepayers. Synapse reviewed the assumptions and computer modeling underlying APCo’s September 2011 IRP and the June 2012 Update. These reviews included an examination of the Companies’ forecasts of peak demand and energy requirements, the inventory of supply-side and demand-side resources considered, and the assumptions regarding the operating characteristics and costs of those resources. Synapse also verified the Companies’ projections of revenue requirements for each of its strategies using Strategist, the same computer simulation model APCo used, and then evaluated alternative strategies using that computer model. Finally, Synapse identified key uncertainties and risks associated with the resource portfolios the Companies evaluated.
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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. Project work for the 2012 proceeding completed in April 2013.
For this project, Synapse provided targeted support to the Energy Foundation and nongovernmental organizations on coal plant economics, including the framework for retrofit vs. retire decision-making, costs of emission controls, benefits of coal retirement, impacts on utilities and their customers, and prioritization of strategic opportunities.
The Ohio Office of Consumer Counsel (OCC) retained Synapse to assist in its review of an application by Duke Energy Ohio for establishment of a revenue requirement and corresponding charge for the Company’s provision of generating capacity service. Rick Hornby filed expert testimony in March 2013 recommending that the Commission reject the Company’s application. He also presented recommendations regarding cost allocation and rate design in the event that the Commission decided to approve the Company’s application. The Commission ultimately rejected the Company’s application.
Synapse provided Earthjustice, Sierra Club, and the Environmental Integrity Project with a report commenting on the economic analysis used to develop the EPA’s newly released proposed Steam-Electric Effluent Limitations and Guidelines (ELGs). For this project, Synapse analyzed the industry-wide affordability of the controls proposed by EPA, the benefits of the ELGs, and the reasonableness of the EPA's assumptions regarding uncertainty. Synapse replicated portions of EPA's cost-benefit analysis to confirm accuracy and examined the impact of changes in underlying assumptions on cost-benefit results.
On behalf of the Prince Edward Island Regulatory and Appeals Commission, Synapse analyzed the projected costs and the overall economic impact of a proposal by the City of Summerside to bypass the transmission system of Maritime Electric with a new 138 kV transmission line.
Ohio Manufacturers Association retained Synapse to help analyze and suggest changes to proposed legislation regarding state policy on utility compensation for energy efficiency as well as on standards for energy efficiency and renewable energy.
On behalf of the Nova Scotia Utility and Review Board, Synapse assessed the Maritime Link transmission project proposal, which contemplates a transmission link to Newfoundland and participation in a hydroelectric development project. The assessment focused on determining if the Maritime Link project is the lowest, long-term cost option available for Nova Scotia to meet its 40% renewable energy requirement for the year 2020. Synapse also assessed the overall economics of the proposal, as compared to alternative renewable energy options (such as Nova Scotia wind resources, including any required transmission improvements required to reliably support increased wind output). For the alternative option, Synapse reviewed estimates of capital cost requirements for wind integration, the need for different asset groups in order to integrate wind, and the relative flexibility (ramping and unit commitment characteristics) of the thermal fleet of resources in Nova Scotia. Synapse also reviewed requirements for additional transmission system development in order to facilitate integration of wind resources.
On behalf of the Sierra Club, Synapse submitted testimony to the Public Utilities Commission of Nevada regarding the application of NV Energy, Inc. and MidAmerican Energy Holdings Company for approval of a merger (docket no. 13-07021). Testimony addressed questions of market power raised by the proposed merger and provided perspective on the actions and recent corporate behavior of PacifiCorp, the single largest regulated neighbor of the utilities and a MidAmerican subsidiary. Settlement resulted in a firm commitment to retire uneconomic coal units in Nevada.
Testimony of Jeremy Fisher Regarding Proposed Merger of NV Energy, Inc. and MidAmerican Energy Holdings Company
Wilmer Cutler Pickering Hale and Dorr LLP (Wilmer Hale) engaged Synapse on behalf of the Vermont Department of Public Service to serve as experts in the review of Entergy’s petition for a certificate of public good to continue operation of the Vermont Yankee Nuclear Power Station.
Synapse conducted on behalf of the EPA an analysis of the participation of energy efficiency (EE) in the PJM Reliability Pricing Model (RPM) capacity market. For this project, Synapse provided a summary of the amount of EE that has participated in previous RPM Base Residual Auctions and estimated revenues received by EE providers from the RPM auctions; identified utility participants and the amount of EE bid into the RPM by each participant; and identified potential areas of further research that could provide greater insight into the potential for EE to impact PJM’s capacity prices, electricity resources, and other factors.
Synapse performed analysis for the Sustainable FERC project examining the Eastern Interconnection Planning Collaborative (EIPC) process. The work included a more comprehensive summarization and interpretation of the costs and the benefits of the three modeled scenarios from Phase 2 of the EIPC analyses (1 – nationally implemented federal carbon constraint, 2 – regionally implemented national RPS, 3 – business as usual). Synapse's work addressed key issues not fully fleshed out in the EIPC reports, and suggested next logical steps for further analysis. Synapse also reviewed and discussed the extent to which certain changes in core assumptions from the EIPC work might have been useful. Those potential changes included, but were not limited to, variables used in the Phase 2 and/or Phase 1 analyses: 1) wind capital costs, 2) wind performance, 3) system flexibility (supply and demand resource), 4) demand side costs (EE/DR), 5) wind integration costs, 6) coordination across regions.
An Expanded Analysis of the Costs and Benefits of Base Case and Carbon Reduction Scenarios in the EIPC Process
Synapse provided expert testimony and analysis on behalf of the Sierra Club for a PacifiCorp general rate case in Oregon regarding the prudence of environmental retrofits undertaken in 2008-2009. Synapse analyzed the decision-making process of PacifiCorp during that timeframe, reviewed the standing of environmental regulations at the time, and determined that the economic justification given for the coal plant retrofits did not merit a prudence finding. The Oregon Public Utility Commission agreed with Sierra Club and ultimately found that costs were not prudently incurred. The Commission imposed a 10 percent disallowance on the retrofits ($17 million) and required a refund to ratepayers in early 2013.
Direct Testimony of William Steinhurst Regarding PacifiCorp’s Filing of Revised Tariff Schedules for Electric Service in Oregon
Surrebuttal Testimony of Jeremy Fisher Regarding PacifiCorp’s Filing of Revised Tariff Schedules for Electric Service in Oregon
Surrebuttal Testimony of William Steinhurst Regarding PacifiCorp’s Filing of Revised Tariff Schedules for Electric Service in Oregon
Atlantic City Electricity Company (ACE) petitioned the New Jersey Board of Public Utilities to approve a rate base increase by approximately $69.7 million. ACE estimated that it will increase the average monthly residential bill by about 7%. Synapse provided consulting services and performed an assessment of the reliability of the ACE distribution system under the commitment made as part of its Reliability Improvement Plan on behalf of the New Jersey Division of Rate Counsel.
This project sought to determine the health damages from air emissions that could be avoided by implementing energy efficiency (EE) or renewable energy (RE) at specific areas in the PJM Interconnect. Synapse modeled displaced generation and emissions from EE/RE using the PROSYM model, and a Boston University team determined the discrete health impacts imparted by the largest generators in PJM. Using this information, the project team created a tool to determine the health impacts that are avoidable by implementing EE/RE throughout various locations in the Interconnect.
Synapse assisted the Nevada State Office of Energy in evaluating the potential business case for accessing the state's renewable energy resources for export to California. Synapse evaluated a number of renewables-oriented transmission build-out scenarios and conducted an IMPLAN model analysis of the economic impacts of renewable generation and transmission investments in the state. Synapse also identified a number of cost allocation and policy issues that would have to be addressed by Nevada lawmakers and/or regulators.
Synapse analyzed the benefits to consumers resulting from the combination of increased wind and supporting transmission in the PJM Interconnection. Synapse identified wind/transmission build-out scenarios for PJM, determined the energy effects associated with the scenarios using the PROSYM production cost model, and estimated transmission costs associated with the scenarios. Based on this analysis, Synapse provided an estimate of the total cost impacts of the wind/transmission build-out scenarios relative to a baseline of expected wind and transmission in PJM.
Synapse prepared a report for the Regulatory Assistance Project examining best practices in electric utility integrated resource planning. Synapse researched and discussed specific integrated resource plan (IRP) statutes, regulations, and processes in Arizona, Colorado, and Oregon; examined "model" utility IRPs from Arizona Public Service, Public Service Company of Colorado, and PacifiCorp; and developed recommendations for prudent integrated resource planning. Our report provided recommendations for both the IRP process and the elements that are analyzed and included in the resource plan itself. These elements include load forecast, reserves and reliability, demand-side management, supply options, fuel prices, existing resources, and environmental costs and constraints, among others.
Synapse provided a report on the benefits to consumers from the proposed CAFE standards. This included rebutting a study from the National Automobile Dealers Association (NADA), a review of other studies on the savings from fuel efficiency standards, and our own estimate of the net savings from the newly proposed rules.
Synapse helped to develop a blueprint of a cost-effective, sustainable future for the District of Columbia in regard to electricity supply and consumption. Synapse established a reference case through 2030 and researched the potential for additional energy efficiency, photovoltaics, combined heat and power, and wind purchases in the District. The study evaluated changes in air emissions and rate and bill impacts.
Synapse prepared an analysis of the clean energy resource options available to replace the power from the Indian Point Energy Center. The report included an assessment of the need for new capacity to meet reliability requirements in the event that Indian Point's operating license is not extended. It also included an assessment of the energy efficiency, combined heat and power, distributed generation, and renewable resources that could be used to meet this need. Synapse also assisted the National Resources Defense Council in preparing comments to the New York Public Service Commission regarding the contingency plan for replacing the Indian Point nuclear plant.
Indian Point Replacement Analysis: A Clean Energy Roadmap (Presentation)
Synapse assisted Sierra Club with a clean energy plan for Washington State, which advocates the replacement of imported coal generation. Synapse provided estimates of job impact factors from energy efficiency, wind, solar, and natural gas in Washington. The results were presented to the Governor and the Washington Climate Legislative and Executive Committee.
Synapse investigated issues related to the Colstrip Generating Station's compliance with New Source Review permitting requirements as part of the Clean Air Act.
Synapse provided consulting services to support the Connecticut office of the AARP in its review of the implementation of various energy polices established in Public Act 11-80. This work included reviewing assumptions and proposals regarding New England gas infrastructure considered during development of the Connecticut 2013 Integrated Resource Plan, evaluating the procurement strategy for standard offer service, and evaluating Connecticut Light & Power’s proposal for residential sector time-of-use pricing enabled by smart meters.
Synapse provided consulting services to the Connecticut AARP office on the state's Comprehensive Energy Strategy (CES) and on proposed changes to the state's Renewable Portfolio Standard (RPS).
On behalf of Clean Wisconsin, Synapse evaluated the requirement, cost, efficacy, and economics of installing a unique multi-pollutant control system, known as ReACT, at Wisconsin Public Service Company’s Weston 3 coal station in Marathon County, Wisconsin (Docket 6690-CE-197). Synapse provided direct, rebuttal, and surrebuttal testimony for the case, and answered inquiries in deposition and hearings. Synapse and subcontractor Ron Sahu presented arguments regarding the parameters of the model used by the Company, attention to risk of greenhouse gas regulation or legislation, capacity market pricing, and the price and operational risks associated with implementing a completely new technology. The Commission recognized significant risk in the decision and set cost boundaries.
Rebuttal testimony regarding Wisconsin Public Service Corporation’s application for authority to construct and place in operation a new multi-pollutant control technology system for Unit 3 of Weston Generating Station
Surrebuttal testimony regarding Wisconsin Public Service Corporation’s application for authority to construct and place in operation a new multi-pollutant control technology system for Unit 3 of Weston Generating Station
Synapse prepared testimony on behalf of the Sierra Club regarding Kentucky Power's proposal to purchase a 50 percent share of a coal plant from an affiliated utility. The testimony focused on integrated resource planning practices and the opportunities in Kentucky for energy efficiency resources, renewable resources, and other lower cost alternatives to the coal purchase. It also focused on affiliate transaction concerns, proper valuation of asset sales between affiliates, and the likely market value of the coal plant at issue. This project included development of a settlement, as well as cross-examination at hearings.
The Danish Energy Agency (DEA) together with partner organizations and a group of developing countries initiated a project to identify key assumptions and methodologies used across a range of developing countries in setting their national greenhouse gas emissions baselines. Synapse contributed to a joint publication by finalizing existing drafts of the introductory sections and providing written comments on drafts from developing country partners.
On behalf of the Delaware Public Service Commission, Synapse evaluated Delmarva Power and Light Company’s 2010 Integrated Resource Plan (IRP). Synapse had previously developed detailed comments on Delmarva’s 2006 and 2008 IRP filings. For this project, Synapse focused on the following key areas of interest: compliance with the January 1, 2010 IRP regulations; the role of demand-side resources in meeting standard offer service (SOS) customer needs; the choice of resource portfolio used to meet SOS needs; and the options for development of gas-fired generation to meet a portion of SOS supply requirements.
Synapse prepared a report for RAP in response to the expressed interested of European policymakers, including the electric power team at Europe’s Agency for the Cooperation of Energy Regulators (ACER). The report focuses on the ways that demand response resources effectively participate in and improve the performance of coordinated electric systems in the United States. Additionally, the report reviews the many types of services that demand response can provide, and the early history of demand response programs in the United States. The bulk of Synapse's research examined the specific applications of demand response in several US regions. This report includes numerous examples of demand response successfully providing reliable system services at competitive prices, and ends with lessons learned and key challenges for the near future.
Based upon the report, Synapse's Doug Hurley prepared materials for and then presented at two events with European Regulators. The first was a workshop in Ljubljana with the staff of the ACER, and the second was a demand response symposium in Brussels.
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