As a continuation of previous work, Synapse provided NS UARB with consulting services on energy efficiency issues. Specific areas where Synapse provided technical support and analysis included: rate and bill impacts, non-energy benefits, methodology to determine program incentives, and benefits of location-specific efficiency targeting.
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Comments on EfficiencyOne’sJanuary 21, 2019 Locational DSM Pilot –DSMAG Update
In 2018, Prince Edward Island Energy Corporation (PEIEC) filed an application (the Application) for approval of its 2018-2021 Energy Efficiency and Conservation Plan (Plan) with the Prince Edward Island Regulatory and Appeals Commission (the Commission or IRAC). Carr, Stevenson, and MacKay hired Synapse Energy Economics, Inc. (Synapse) to assess the Plan, in particular whether the Plan is likely to satisfy legislative requirements. To this end, Synapse reviewed the Application, issued information requests, and sponsored an expert report. The report considered the reasonableness of PEIEC’s Plan in terms of scope, cost allocation, and projected savings, participation, costs, and benefits. The expert report built upon Synapse’s 2016 comprehensive, best practice report for PEI on energy efficiency program and policy requirements. Project completed May 2019.
The New Jersey Division of Rate Counsel retained Synapse to review PSEG’s base rate adjustment proposal based on the roll-in schedule of the PSEG’s Energy Strong investment program.
California’s ambitious state law SB 350 aims to increase renewable energy generation and achieve “widespread transportation electrification” across the state. Pursuant to this law, California’s largest investor-owned utilities are proposing to make over $1 billion in transportation electrification investments. These investments are accompanied by new rate designs to support adoption of electric vehicles (EVs) and encourage charging in a manner that is consistent with electrical grid conditions. Synapse was retained by NRDC to evaluate the utilities’ rate design proposals for public fast-charging facilities, commercial fleets, and residential customers.
Testimony of Melissa Whited on Commercial EV Rates
Testimony of Melissa Whited on Fast Charging Infrastructure and Rates
Testimony of Melissa Whited on Residential Rates
Rebuttal Testimony of Melissa Whited on EV Rate Design
Electric Vehicles are Not Crashing the Grid
Synapse is providing the Maryland Office of People’s Counsel (OPC) with technical assistance and testimony in Case No. 9406 regarding Baltimore Gas and Electric Company’s (BGE) electric rate increase request to recover costs for smart grid implementation and other costs. The increase of approximately $135.2 million is intended to pay for implementation of advanced metering infrastructure and underground conduit costs in Baltimore. Synapse staff and subcontractor Nancy Brockway submitted testimony covering the benefit cost analysis of the advanced meter infrastructure investments and cyber-security/ privacy concerns associated with the implementation of advanced meter infrastructure investment across the BGE service territory.
Synapse has been retained to evaluate National Grid’s Massachusetts rate design proposals, filed as part of its 2016 rate case. In its application, the Company proposed to impose tiered customer charges on residential and small commercial customers intended to act as a proxy for a demand charge. Synapse submitted testimony that demonstrated why the Company’s proposal not only failed to improve customer equity, but would also be unnecessarily complex, difficult for customers to respond to, and would undermine price signals for energy efficiency and distributed energy resources. Specifically, Synapse conducted statistical analysis to show that the Company’s proposed proxy for a demand charge was no better of an indicator of customer demand than an energy charge, and also failed to account for customer demand diversity and the coincidence with system peak demands.
Rebuttal Testimony of Tim Woolf and Melissa Whited Regarding National Grid Rate Design Proposal
Synapse is reviewing performance incentive mechanisms for HELCO and HECO on behalf of the Division of Consumer Advocacy.
Indiana Michigan Company (I&M) submitted an application to the Indiana Utility Regulatory Commission seeking a certificate of public convenience and necessity to install Selective Catalytic Reduction at Rockport Power Plant Unit 2 near Rockport, Indiana. Synapse assessed the analysis conducted by American Electric Power Generating Services on behalf of I&M in support of the application. Specifically, Synapse examined if the installation of the controls would be in the interest of I&M’s ratepayers and if the proposal was consistent with regulatory requirements. On behalf of Citizens Action Coalition of Indiana, Sierra Club, and Valley Watch, Dr. Jeremy Fisher submitted testimony to the Commission recommending that the Commission deny the CPCN on the basis that the Company’s analysis is outdated and Rockport 2 is not a reasonable long-term resource.
2017 annual update of South Carolina Electric & Gas' (SCE&G) avoided costs, to be used in both PURPA QF rates and for Act 236 compliance. Witness Thomas Vitolo, PhD, submitted testimony (Docket No. 2017-2-E).
Synapse provides technical and policy support to the Rhode Island Division of Public Utilities and Carriers. Much of the support includes full participation in the RI Energy Efficiency Collaborative. The work includes all aspects of energy efficiency program design, implementation, and review related to the Narragansett Electric programs, which are some of the most aggressive and successful efficiency programs in the US. It also includes a comprehensive analysis of the rate, bill, and participation impacts of the energy efficiency programs.
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
As new, more stringent federal environmental regulations come into effect, the fleet of U.S. coal-fired power plants is becoming increasingly less economic in comparison to the alternative of electricity market purchases. Numerous industry groups, environmental advocates, and government agencies have published estimates of the U.S. coal capacity at risk of retirement. However, all of these estimates have been conservative in that they have excluded the costs of installing and operating some of the controls expected to be required for compliance with environmental regulations, and/or they have assumed a long-run carbon-emission price of zero. This study explores a more comprehensive set of assumptions, using Synapse's Coal Asset Valuation Tool (CAVT). CAVT (now on version 6.0) is a spreadsheet-based database and model that forecasts the costs for individual coal units to comply with environmental regulations, and compares these forecasts to electricity market prices. It includes cost estimates for all expected environmental retrofits along with carbon prices.
Forecasting Coal Unit Competitiveness: Coal Retirement Assessment Using Synapse Coal Asset Valuation Tool (CAVT)
Synapse provided technical and policy support for several aspects related to the NY REV Initiative. This included drafting detailed comments and reply comments on the New York Utilities' proposed Distribution System Implementation Plans, with an emphasis on ensuring that distributed energy resources are properly planned for and implemented. It also included a detailed review of NY energy efficiency activities and recommendations for how to promote the implementation of all cost-effective energy efficiency resources as part of the NY REV initiatives. This work also included technical support for estimates of avoided distribution costs at constrained locations on the grid; i.e., the "value of D."
The National Standard Practice Manual and the Value of Energy Efficiency in New York
Value of Energy Efficiency in New York: Assessment of the Range of Benefits of Energy Efficiency Programs
Synapse is assisting this group of consumer and environmental advocates with their goal of reducing future transmission costs in New England. Topics will include: (a) properly accounting for energy efficiency in forecasting loads for transmission planning, (b) properly accounting for non-transmission alternatives in transmission planning, (c) participating in ISO-New England’s Strategic Initiative, and (d) providing input to the New England Regional System Plan. This work includes participating in a variety of different forums, including FERC dockets, ISO-NE stakeholder processes, NEPOOL technical committees, and discussions with a variety of New England stakeholders. The E4 Group is composed of the Maine Office of the Public Advocate, Grid Solar, Environment Northeast, Conservation Law Foundation, and Maine Industrial Energy Consumers.
Challenges for Electric System Planning
2016 NECPUC Symposium Presentation
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 prepared a Technical Brief that provides an overview of benefit-cost analysis techniques for reviewing utility proposals for grid modernization investments. The Brief is written for regulators, consumer advocates, and other stakeholders who seek to determine whether grid modernization proposals are in the public interest; especially proposals for utility-facing technologies that help advance reliability, resilience, advanced metering, and the integration of distributed energy resources. The Technical Brief addresses some of the most challenging aspects of benefit-cost analysis for grid modernization, such as determining the appropriate cost-effectiveness test to use, accounting for interactive effects between grid modernization components, and accounting for qualitative benefits. Tim Woolf presented the material in a training course for consumer advocates at the meeting of National Association of Utility Consumer Advocates in November 2018. He also presented the material at the Mid-Atlantic Distribution Systems and Planning Training with the NARUC-NASEO Task Force on Comprehensive Electricity Planning on March 8, 2019.
Tampa Electric Company (TECO) filed an application to construct a new 1090 MW gas-fired power plant at a cost of $895 million. This so called “modernization” project sought to repower an existing steam turbine at the site of the coal- and gas-fired power plant at the Big Bend Power Station in Tampa, Florida. Synapse provided analysis and expert testimony on behalf of the Sierra Club to evaluate the need for, and impact of, the proposed plant.
Synapse found that TECO's application did not demonstrate a need for the electricity generated by this new gas plant, and made numerous dubious claims about the project’s environmental and economic benefits. Witness Bruce Biewald submitted testimony on the climate damages that will result from the construction of the gas plant. Witness Devi Glick submitted testimony assessing the electrical energy needs of TECO’s customers, and identifying ways to meet those needs through better system planning and cleaner, lower cost alternative resources.
The Proposed Plant at Big Bend: A Review of Climate Impacts
The late January 2019 Polar Vortex weather event brought extreme temperatures to the upper Midwest through New England – the same stretch of the country where the most fossil fuels are used to heat buildings. As it becomes clear that a decarbonized electric grid is possible, “#ElectrifyEverything” has become a rallying cry for the path to transportation and building decarbonization. In this webinar, we explore the hypothetical: What if all the buildings from the Dakotas, to the Ohio River Valley, through Maine were heated with cold climate heat pumps instead? We estimate the impact on hourly peak electric loads, and we use this to tee up and discuss questions about what a cost-effective plan to decarbonize these buildings would need to address.
The electrification of transportation systems can bring substantial economic and public health benefits. Synapse’s new guidebook for consumer advocates describes how to evaluate the potential impacts of EVs on customers’ electricity rates, health, and vehicle expenditures. It also describes some of the policies that can be implemented to help ensure that transportation electrification occurs in a manner that allows all customers, particularly low-income and other vulnerable groups, to share in the benefits while not unfairly bearing the costs.
Synapse's Ben Havumaki and Tim Woolf lead an afternoon conversation about grid modernization that both addresses broad themes and zooms into the nitty gritty. Topics include:
- Overview of key concepts in grid mod
- Benefit-cost analysis, including how to select an appropriate cost test for grid mod projects
- Challenges in quantifying costs and benefits
- Customer equity
- Best practices
- Case studies of recent utility-facing grid modernization plans
Sierra Club retained Synapse to conduct an updated economic analysis of the J.K. Spruce coal plant, located near San Antonio, Texas. Synapse evaluated the recent economic performance of the plant, the likely performance of the plant over the next two decades, and the availability of cost-effective renewable alternatives to Spruce. Synapse found that (1) the Spruce plant likely lost more than $100 million relative to the market between 2013 and 2018; (2) Spruce is likely to continue to lose money relative to the market in the near term; (3) Spruce will only become profitable relative to the market over the long term if a series of favorable conditions hold; (4) CPS would likely save money by replacing the Spruce plant with renewable resources, even under market conditions favorable to the Spruce units; (5) replacing Spruce with renewables would reduce emissions and associated regulatory risks in addition to likely reducing costs; (6) retiring uneconomic coal units would be unlikely to harm CPS's credit rating; and (7) the current planned Spruce retirement dates are not based in a sufficiently robust and transparent planning process. We concluded that CPS should promptly engage in a thorough, public planning process to evaluate the potential near-term retirement of the Spruce units.
On behalf of Maine Renewable Energy Association and other Maine stakeholders, Synapse partnered with Sustainable Energy Advantage to assess the impacts of expanding Maine’s Class I renewable portfolio standard (RPS) to reach 50 percent by 2030. This analysis found that expanding the RPS would: Create 170 jobs per year between 2020 and 2030; Improve public health by curbing air pollution, avoiding $500,000 per year in public health damages between 2020 and 2030; Add 700 MW of new, in-state renewable energy projects; Result in minimal impact to Maine’s ratepayers, with only slight increases in residential bills of $1.16 to $1.76 per month between 2020 and 2030; and Reduce Maine’s reliance on fossil fuels by 5% and curb greenhouse-gas emissions from the electric sector attributable to Maine by 55%. This project is currently ongoing.
Maine RPS Analysis Appendix
Burlington, Vermont’s municipal electric utility, Burlington Electric Department (BED) contracted with Synapse Energy Economics (Synapse) and Resource Systems Group (RSG) to develop a roadmap to provide clarity and insight into how the City could best achieve its Net Zero Energy by 2030 goal. The City’s Net Zero Energy goal is defined as reducing and eventually eliminating fossil fuel use from the heating and ground transportation sectors. Burlington currently sources 100 percent of the City’s electricity needs from renewables. Burlington’s Net Zero Energy goal is the most ambitious climate goal established by any community in the United States to date for both its rapidity and comprehensiveness.
This roadmap is a strategic analysis of the major steps or milestones needed to reach the goal with supporting data and recommended next steps for achieving the goal. The Synapse/RSG team:
- developed a 2018 baseline of energy use across all sectors;
- projected a business-as-usual trajectory through 2030;
- analyzed four pathways to net zero energy by 2030, including the magnitude and cost- effectiveness of each opportunity; and,
- detailed a host of policies and strategies with consideration for impact, cost-effectiveness and equity.
The intended audience for this roadmap is implementers of climate action goals, strategies and policies nationwide: including community and state leaders, partner organizations, utilities, and community members.
Synapse prepared testimony on energy efficiency targets and incentives on behalf of the Natural Resources Defense Council in the recent Con Edison rate case. The testimony addressed the need to develop electricity and gas efficiency savings targets that are consistent with the Commission's statewide targets as well as the state's carbon emission reduction goals. It also addressed the need to provide sufficient budget to allow the utilities to provide the efficiency services necessary to meet the targets. Synapse also recommended modifications to the utility's cost-effectiveness practices to be consistent with the Commission's recent order on Benefit-Cost Analyses and to ensure the implementation of all cost-effective efficiency resources. Finally, the testimony addressed the energy efficiency earning adjustment mechanisms (i.e., performance incentive mechanisms) to ensure that Con Edison has sufficient incentive to implement effective efficiency programs, but not overlapping or unduly excessive incentives.
Comments on Comprehensive Energy Efficiency Initiative Case 18-M-0084
CEP Comments on Future of Value Stack
In 2018, Duke Energy submitted to the North Carolina Department of Environmental Quality its analysis of options for the closure of eight of its coal ash basins spread over six sites. The Southern Environmental Law Center commissioned Synapse Energy Economics, Inc. to review Duke’s Summary Reports and the Company’s analysis on trucking impacts, community and regional impacts, environmental impacts, and the estimated closure costs and schedules. Our resulting report describes how Duke's evaluation framework was designed to skew results in favor of its “Closure-in-Place” option, and in fact, to effectively ignore environmental impacts and risks. On April 1, 2019, the North Carolina Department of Environmental Quality ruled that Duke Energy must remove all ash from existing unlined landfills and move the ash to new, lined landfills.
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