FirstEnergy’s Ohio utilities (Ohio Edison, Cleveland Electric, and Toledo Edison) filed an application before the Public Utility Commission of Ohio seeking approval of an Electric Security Plan (“ESP”) and related Retail Rate Stability Rider (“Rider RRS”). FirstEnergy claims that customers will receive benefits of over $2 billion over the length of the plan due to the Companies’ projections of revenues from capacity and energy market sales. On behalf of Sierra Club, Synapse expert witness Tyler Comings submitted testimony focusing on the assumptions and analysis used by the Companies to support the Rider RRS, and the policy implications and risks associated with the proposed transaction.
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Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Second Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Third Supplemental Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Rehearing Testimony of Tyler Comings Evaluating the Assumptions and Analysis Used by FirstEnergy Ohio in Support of its Application for Approval of an Electric Security Plan and Related Retail Rate Stability Rider
Recently, there has been a substantial increase in the number of utilities that propose to recover more of their costs through monthly fixed charges rather than through variable rates. Synapse prepared a report for Consumers Union that documents the current trend toward utilities proposing substantial increases in fixed electricity charges, describes the theoretical flaws behind fixed charges, analyzes their impact on consumers, and proposes alternatives.
Synapse and Consumers Union held a webinar on February 10, 2016 based on the report: Caught in a Fix: The Problem with Fixed Charges for Electricity.
Caught in a Fix: The Problem with Fixed Charges for Electricity
Caught in a Fix - Webinar Slides
Synapse provided technical support for Sierra Club’s participation in the Florida Power & Light (FPL) 2016 Rate Case. Synapse reviewed three major capital investments included in FPL’s 2016 10-Year Site Plan: $800 million to replace retiring gas turbines; $450 million to upgrade combustion turbine compressors; and $400 million to build three solar plants (224 MW combined). The analysis addressed whether FPL considered lower cost, lower risk alternatives to meet its planning reserve margin goal, whether new units were necessary to meet its goal, and whether solar resources could have been procured at lower cost.
Synapse supported Sierra Club in the evaluation of the Georgia Power 2016 Integrated Resource Plan. Specifically, Synapse reviewed Georgia Power Company’s Unit Retirement Study (URS), which was conducted by the company to assess the economic benefit of continuing operation of its major fossil fuel power plants. Based on the URS, Georgia Power recommended decertifying one coal-fired unit and four combustion turbines. Synapse’s analysis of the URS uncovered substantial issues with its model and assumptions. Dr. Jeremy Fisher and Tim Woolf submitted expert testimony demonstrating that, contrary to Georgia Power’s URS findings, eight generators are not economically viable.
Exhibits for Direct Testimony of Jeremy Fisher regarding Georgia Power 2016 Integrated Resource Plan
Massachusetts’ Green Communities program helps the state’s 351 cities and towns find and successfully implement clean energy solutions. To receive Green Community designation, communities must develop and implement a plan to reduce energy use by 20 percent within five years and meet additional criteria including allowing for permitting and siting of renewable energy, purchasing fuel-efficient and alternative fuel vehicles, and adopting more stringent building codes. The Massachusetts Department of Energy Resources engaged Synapse to review Green Community Annual Reports, verify whether municipalities have reached their 20 percent energy reduction goal, and develop a Progress Report for the program highlighting achievements to date. Synapse will also identify strategies that are effective across towns, provide support to towns to meet their energy reduction goal, and make recommendations to continue to advance and improve the program. Synapse developed the Green Communities Program 2016 Progress Report, available here, and is currently developing the 2017 report.
Southern Environmental Law Center retained Synapse to review Dominion Virginia Power’s application for a Certificate of Public Convenience and Necessity for its proposed Greensville County Power Station, a new natural gas combined-cycle plant. Synapse’s analysis found that the Company’s need analysis overstated its electric load and did not give appropriate consideration to alternative resource choices. On behalf of environmental respondents, Rachel Wilson submitted testimony to the Virginia State Corporation Commission demonstrating that Dominion overstated the need for the Greensville NGCC and recommending that the Commission deny the Company’s petition for a CPCN and an associated rate increase.
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.
On behalf of Not Another Power Plant and Sierra Club, Synapse’s Bob Fagan submitted Direct and Surrebuttal expert testimony to the Connecticut Siting Council regarding the Killingly Energy Center, a 550 MW combined cycle power plant proposed for Killingly, Connecticut. He testified at two separate Siting Council hearings concerning the proposed plant. Mr. Fagan’s testimony clearly demonstrated that there are no short-term or longer-term reliability needs for the proposed plant. Further, increased renewable resources and energy efficiency required to meet increasing greenhouse gas emission limits will provide more than sufficient energy and capacity to meet reliability needs.
Surrebuttal Testimony of Bob Fagan Regarding Proposed Killingly Energy Center
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). The Fee Structure Model (FSM) is a tool first developed by Synapse for M-RETS in September 2012. The FSM uses historical data from both publicly available sources and M-RETS internal tracking to project future annual revenues. A key part of this forecast is an annual calibration of the tool to determine whether significant revisions should be made to the FSM. In its comparison of 2015 projected vs actual revenues, Synapse identified and then addressed two areas for updates in 2016, subscriptions and voluntary retirements.
Synapse is providing technical support and expert testimony to the Conservation Law Foundation regarding a series of Massachusetts Department of Public Utilities natural gas pipeline dockets. In these dockets, electric distribution companies have petitioned to embed the costs of natural gas transmission pipelines in customer electric bills. In the most recent dockets (MA 15-181 and MA 16-05), Eversource and National Grid submitted separate analyses on the long-term economic benefits of Algonquin’s proposed Access Northeast natural gas pipeline infrastructure project. Synapse assessed the methodology and assumptions of the benefits in the analyses submitted by Eversource and National Grid. Specifically, Synapse reviewed the results of scenarios modeling New England’s future electric sector with and without the Access Northeast pipeline to determine whether the modeling assumptions (1) were consistent with compliance with state and federal environmental laws and (2) represented “most likely” projections of uncertain future conditions.
Direct Testimony of Elizabeth A. Stanton Regarding the National Grid Analysis of Economic Benefits of Proposed Access Northeast Gas Pipeline
Synapse provided expert support to the Conservation Law Foundation (CLF) in its New Source Review (NSR) suit over modifications made to Merrimack Station Unit 2 in New Hampshire.
South Carolina Electric and Gas Company (SCE&G) filed a petition (Docket No. 2016-224-E) requesting that the Public Service Commission of South Carolina approve an approximately $852 million increase in the cost estimate for the construction of two new units at the V.C. Summer nuclear power plant. SCE&G has repeatedly raised rates to recover financing costs of the plant, resulting in a substantial impact on customer bills. South Carolina Coastal Conservation League (SCCCL) retained Synapse to analyze the opportunity for energy efficiency programs to mitigate the bill increases associated with SCE&G’s petition. On behalf of SCCCL, Senior Associate Alice Napoleon submitted testimony and an accompanying report in which she reviewed SCE&G’s energy efficiency efforts to date and presented recommendations for expanding SCE&G’s energy efficiency programs in order to provide all customers with opportunities to lower their bills.
Direct Testimony of Alice Napoleon regarding South Carolina Electric and Gas Energy Efficiency Efforts
Vermont Department of Public Service retained Synapse for this special project to address New England stakeholder issues regarding the electric grid and related topics. Synapse researched, analyzed, and provided recommendations on numerous topics. Synapse also provided advocacy on behalf of VT DPS in the stakeholder process.
Synapse and Raab Associates provided technical and facilitation support to New Hampshire PUC staff for a stakeholder process to address grid modernization issues and policies for the state. Synapse assisted with developing agendas for stakeholder meetings, providing technical and policy analyses, and communicating the results of those analysis. After the stakeholder process, Synapse assisted with compiling initial and final reports with recommendations from the stakeholder group.
In this webinar from June 2, 2016, Synapse Senior Associate Pat Knight highlights a critical issue under discussion in the current RGGI Stakeholder Process: to comply with state climate laws, RGGI states must double emission reductions to 5 percent each year as modeled in Synapse’s recent report “The RGGI Opportunity 2.0”. He also discusses the potential impacts of the recent Massachusetts Supreme Judicial Court ruling on the Global Warming Solutions Act with Larry Chretien of Mass Energy Consumers Alliance (a co-plaintiff in this case), and talks about the measures that could be taken to achieve concrete CO2 emissions reductions.
Renewables as a fraction of all new electric generation capacity has been trending upward for a half decade or more. However, the construction of new wind, solar, and other renewable generation capacity is far from uniformly distributed across the contiguous United States. In this webinar from June 22, 2016, Dr. Thomas Vitolo and Patrick Luckow investigate the extent to which regulatory policies, resource potential, utility structure, and financial considerations have influenced the deployment of renewable generators throughout the country, and how small changes in any of these factors can yield enormous differences in deployment.
On behalf of Counsel to the Nova Scotia Utility and Review Board (NSUARB), Synapse assessed Nova Scotia Power's (NSPI) advanced metering infrastructure pilot proposal. NSPI requested approval to deploy advanced (“smart”) meters to up to 1,000 customers at a cost of $8.2 million. Ms. Alice Napoleon identified multiple issues with the proposal, including, among other things, that the pilot period would neither provide sufficient time for data collection nor cover the period of highest system demand; that the pilot’s size was not adequately justified; that complementary programs to help customers experience the benefits from implementation of AMI were omitted; and that the proposed network for the pilot is not consistent with the network that may be required for full implementation. Ms. Napoleon concluded that the design of the proposed pilot would not provide a solid basis for determining whether the costs and benefits associated with AMI justify a full roll out. Ms. Napoleon recommended that NSUARB not approve the current pilot application based on the current record of evidence.
Synapse provided analysis and expert testimony on behalf of Sierra Club in Oklahoma Gas & Electric’s application before the Oklahoma Corporation Commission seeking approval to install dry scrubbers at the Sooner generating facility. Synapse’s Tyler Comings evaluated the economic case for the retrofits with a focus on the assumptions used for natural gas price risk and fuel diversity. Mr. Coming’s testimony found that installing dry scrubbers at Sooner is not the least cost option. Mr. Comings recommended that the Commission deny the proposal. Should the Committee accept the proposal, Mr. Comings recommended it do so with conditions that would protect ratepayers.
Earlier testimonies from the Oklahoma Gas & Electric CPCN Proceedings can be found here.
Responsive Testimony of Tyler Comings on Oklahoma Gas and Electric Application for Approval to Install Dry Scrubbers at the Sooner Generating Facility
Synapse supported Delaware Riverkeeper in drafting comments to Federal Energy Regulatory Commission on the PennEast pipeline Draft Environmental Impact State, focused on the potential impacts on natural gas drilling in the state.
Delaware Riverkeeper's filed comments are available here.
On April 19, 2016, Potomac Electric Power Company (Pepco) requested approval for an electric rate increase of approximately $126.8 million to recover costs including, but not limited to, the implementation of advanced metering infrastructure (AMI) in its service territory. Maryland Office of People’s Counsel engaged Synapse to evaluate the assumptions and methodologies used by Pepco to determine the cost-effectiveness of its AMI deployment. Synapse’s analysis found that Pepco’s analysis overstated both the market-side and operational benefits of the AMI program. Max Chang submitted direct testimony to the Maryland Public Service Commission on behalf of Maryland OPC demonstrating that the program is essentially break-even and recommending that the Commission require Pepco to provide regular analyses of the program’s cost-effectiveness.
Lawrence Berkeley National Laboratory (LBNL) has prepared a series of technical reports on Future Electric Utility Regulation, which examine issues related to incremental and fundamental changes to electric industry regulation in a future with high distributed energy resource (DER) levels. Synapse provided research and analysis to support LBNL in producing a technical report on performance-based regulation in a high DER future. The report: summarizes the full suite of mechanisms used in various types of PBR; compares ratemaking and regulation of utilities under cost of service versus PBR paradigms; explains how to incorporate performance-based metrics focused on DER; presents key subtopics from the perspective of both the electric utility and the customer/broader public interest; describes a taxonomy of issues to consider in determining whether to implement some elements of PBR or comprehensive PBR; and describes criteria state utility commissions can consider to evaluate whether to adopt some form of PBR in the context of a high DER future.
Performance-Based Regulation in a High Distributed Energy Resources Future (webinar slides)
Synapse conducted a second supplementary audit of the operation of the Nova Scotia Power Inc. load retention tariff mechanism for Port Hawkesbury Paper pursuant to the Nova Scotia Utility and Review Board Decision Letter of May 23, 2014 in Docket M05803.
Kenji Takahashi presented "Progress and Prospect of U.S. Electricity Policies" at the Citizen's Alliance for Saving the Atmosphere and the Earth (CASA) seminar in Osaka, Japan on July 5, 2016. Presentation in Japanese.
Synapse analyzed the implications of higher fixed charges, time-of-use rates, and minimum bills on customers of Maryland's electric cooperatives. The study focused on the ways that these rate designs would impact low-income customers, low-usage customers, net metering customers, and the ability for Maryland to achieve its energy efficiency goals. This analysis was in response to Maryland Senate Bill 1131, which would have required the Maryland Public Service Commission to approve increases to electric cooperative customers' fixed monthly charges.
Synapse was retained by EPA to evaluate claims of petitioners seeking to stay the Regional Haze Rule Federal Implementation Plan (FIP) for Texas and Oklahoma. Dr. Jeremy Fisher and Mr. Bob Fagan provided declarations regarding the economic impact of the rule and the impact of the rule on transmission planning exercises within the ERCOT region.
OutSmart Power Systems provides commercial, industrial, and institutional facilities with a full energy optimization solution including its own cost-effective submetering, analytics on all circuit-level energy use transitions, and an energy services team focused on actionable, work order-ready efficiency improvement measures. On behalf of OutSmart, Synapse Energy Economics developed a cost-effectiveness screening tool and assessed the benefit-cost ratio (BCR) of OutSmart’s solution, providing program administrators in Massachusetts and others visibility into OutSmart’s cost effectiveness. Our analysis found that their solution is cost-effective with a benefit cost ratio greater than one, assuming a reasonable measure life.
The Brayton Point Power Plant in Somerset, Massachusetts will retire by June of 2017, and give the town an opportunity to influence the fate of the 234-acre waterfront site. On behalf of a coalition of environmental advocates, Synapse has set the assessment in a regional context and reviewed several future options for the site to determine their pros and cons. Options analyzed included building a new natural gas plant on the site and installing a variety of clean energy generation and battery storage units – referred to as a Clean Energy Hub. The resulting report explores the impacts on the local economy in terms of jobs and tax revenues, the Commonwealth’s ability to comply with its Global Warming Solutions Act, and the perceived need for locally generated electricity.
Synapse is engaged in ongoing work on behalf of Appalachian Mountain Advocates (AMA) and the Southern Environmental Law Center to analyze natural gas demand and proposed pipeline expansion in Virginia and the surrounding region. Related to this, AMA commissioned Synapse to assess the cost and potential for renewables in Virginia, including both renewable energy sources built in state and renewable energy produced in the surrounding region and purchased by Virginia. Synapse found that wind and solar energy showed the greatest potential for Virginia considering technical potential, economic feasibility, and integration concerns.
In support of New York State’s nation-leading GHG emissions reduction goals—targeting 40 percent reduction of GHG emissions by 2030 and 80 percent by 2050—the New York State Energy Research and Development Authority (NYSERDA) has begun a process of developing an integrated policy framework to address emissions from the heating and cooling sector. Synapse joined a group of consultants led by Meister Consultants to assist NYSERDA with this effort. More specifically, Synapse assisted NYSERDA and Meister with developing (a) a comprehensive database of costs and performance of Renewable Heating and Cooling (RH&C) technologies such as air-source heat pumps, geothermal heat pumps, solar hot water, and heat pump water heaters; (b) an Excel-based tool to analyze costs and benefits of RH&C technologies; and (c) a state RH&C Policy Framework report. As part of our effort to develop RH&C technology profiles, Synapse also participated in a stakeholder meeting by the Advisory Committee of industry stakeholders and experts and facilitated a working group on air-source heat pumps.
In 2016, Public Service Company of Colorado (PSCo) filed a request for rate design modifications, including a tiered monthly “Grid Use Charge” for all residential customers and a voluntary residential demand – time-of-use rate. The Company’s stated intent for the proposed Grid Use Charge was to act as an interim step before the implementation of a demand charge. On behalf of Energy Outreach Colorado, Synapse conducted an analysis of PSCo’s proposal and Tim Woolf provided expert testimony before the Colorado Public Utilities Commission. Synapse’s testimony challenged the Company’s proposal to move residential customers toward demand charges because such charges are inconsistent with fundamental rate design principles, create inefficient price signals, are complex and difficult for residential customers to respond to, place undue burden on low-usage and low-income customers, and may ultimately increase long-term electricity costs. Project ongoing.
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