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Synapse is providing expert technical consulting services to the Delaware Department of Natural Resources and Environmental Control (DNREC) related to Exelon Corporation’s proposed acquisition of Pepco Holdings Incorporated. Specifically, Synapse reviewed the value of the benefits and commitments of the merger and concerns regarding concentration of ownership, market power, and market manipulation in the wholesale electricity market. Synapse is submitting testimony in the legal proceeding on behalf of DNREC. Synapse performed similar analysis related to the merger on behalf of clients in Maryland, New Jersey, and the District of Columbia.
Direct Testimony of Paul Peterson Regarding Concentration of Ownership, Market Power, and Potential Market Manipulation Related to the Proposed Exelon-Pepco Merger in Delaware
Synapse provided expert technical consulting services to the New Jersey Division of Rate Counsel related to Exelon Corporation’s proposed acquisition of Pepco Holdings. Specifically, Synapse reviewed the Joint Applicants' economic impact analysis; merger-related reliability issues; and concerns regarding concentration of ownership, market power, and market manipulation. Synapse submitted testimony in the legal proceeding on behalf of the NJ DRC. Synapse performed similar analysis related to the merger on behalf of clients in Delaware, Maryland, and the District of Columbia.
Direct Testimony of Paul Peterson on Market Power Issues Related to the Exelon-Pepco Merger in New Jersey
Direct Testimony of Tyler Comings Regarding Economic Impact Analysis in Proposed Exelon-PHI Merger in New Jersey
Synapse is actively working with a group of stakeholders to engage in the development of the Energy Information Administration's 2016 Annual Energy Outlook (AEO), to be released in mid-2016. The AEO is a critical source of publicly available information for public interest stakeholders working to improve planning and decision-making in the energy sector. Synapse is participating in working groups associated with three key areas of the 2016 AEO: the renewable energy sector, the electricity sector, and the residential/commercial buildings sector. Modeling of EPA’s Clean Power Plan will be a major change in the 2016 AEO from previous forecasts. Synapse is working with other stakeholders to participate actively in this process and advocate for reasonable policy and technology assumptions.
AEO Buildings Working Group Meeting Notes - February 18, 2016
AEO Electricity Working Group Meeting Notes - February 10, 2016
AEO Renewables Working Group Meeting Notes - February 9, 2016
AEO Buildings Working Group Meeting Notes – December 8, 2015
AEO Electricity Working Group Meeting Notes – December 8, 2015
AEO Renewable Working Group Meeting Notes – December 7, 2015
Synapse and a team of subcontractors developed projections of electricity and natural gas costs that would be avoided due to reductions in electricity and natural gas use resulting from improvements in energy efficiency. The 2018 report provides projections of avoided costs of electricity and natural gas by year from 2018 through 2035 with extrapolated values for another 15 years. In addition to projecting the costs of energy and capacity avoided directly by program participants, the report provides estimates of the Demand Reduction Induced Price Effect (DRIPE) of efficiency programs on wholesale market prices for electric energy, electric capacity, and natural gas. The report also provides a projection of avoided costs of fuel oil and other fuels, non-embedded environmental costs associated with emissions of CO2, avoided costs of transmission and distribution, and the value of reliability. The 2018 AESC study was sponsored by a group representing all of the major electric and gas utilities in New England as well as efficiency program administrators, energy offices, regulators, and advocates. Synapse conducted prior AESC studies in 2007, 2009, 2011, and 2013.
Avoided Energy Supply Costs in New England: 2013 Report
Avoided Energy Supply Costs in New England: 2011 Report
Avoided Energy Supply Costs in New England: 2009 Report
Avoided Energy Supply Costs: 2007 Final Report
Affidavit Regarding the Avoided Energy Supply Cost 2011 Report
Highlights of AESC 2011 Report: Presentation to the Vermont Public Service Board
Highlights of AESC 2011 Report: Presentation to Efficiency Maine Trust
Highlights of 2009 AESC Report: Presentation to the Vermont Public Service Board
Electricity Cost Highlights of Avoided Energy Supply Costs in New England 2007 Final Report
In 2014-2015, Berkshire Gas in Massachusetts placed a moratorium on new services in part of its territory after identifying distribution capacity constraints and insufficient supply resources. On July 8, 2016, Berkshire Gas filed a petition with the Department of Public Utilities seeking approval of its Long-Range Forecast and Supply Plan (F&SL) under D.P.U. 16-103. The company based its plan on analysis of various resource options to increase access to natural gas for the region as a precursor to lifting the moratorium.
On behalf of the Town of Montague, Synapse reviewed and assessed the reasonableness of Berkshire Gas’s F&SL. Our review of the resource plan revealed that while the plan included energy efficiency and demand response as options, it gave little attention to such resources. Instead, the company recommended investment in extensive and expensive new infrastructure options. We concluded that the company could lift the moratorium by implementing a few simple steps: (a) re-establish curtailable agreements with two large customers that already have dual-fuel capability, and (b) change the way it estimates impacts from current and future energy efficiency programs. We also identified additional demand-side resource potential by analyzing the historical performance of gas energy efficiency programs in New England, current program offerings, and a new gas demand-response program based on internet-connected thermostats. Our analysis concluded that with these expanded demand-side resources, the company could expect future peak load to decline from today’s level over the next five years. Furthermore, the future load forecast could be even lower if it incorporated potential impacts from emerging technologies and other factors. Specifically, electric heat pumps and the state’s existing climate change policies are highly likely to lead to substantial electrification in various sectors and to lower overall gas consumption.
In collaboration with the Lawrence Berkeley National Laboratory, Synapse is assisting the Advanced Manufacturing Office of the U.S. Department of Energy in developing a set of resources (i.e., a toolkit) to demonstrate the value and communicate the approach of the Better Buildings Initiative - Superior Energy Performance (SEP) Accelerator to utilities, regulators, and industrial customers. Integrating input from key energy efficiency program administrators (PAs), Synapse is developing a toolkit providing the necessary information, resources, frameworks for analysis, and case studies that will facilitate the development and deployment of ratepayer-funded SEP program offerings. Among other resources, the toolkit includes a Cost Effectiveness Screening Tool to assist PAs with determining if developing offerings for SEP is likely to achieve positive net benefits, and a SEP Filing Guide to provide PAs with guidance on the information to include in their program plans.
The Los Angeles City Council has mandated that the Los Angeles Department of Water and Power (LADWP), the largest municipally-run utility in the United States, analyze powering 100 percent of demand with renewable energy. To date, LADWP's efforts have been insufficient, as the utility has only published an analysis of a slight increase over current renewable energy targets and is not planning to finalize their 100 percent renewable study until 2020 at the earliest.
Food & Water Watch engaged Synapse to analyze a potential pathway to 100 percent clean energy in Los Angeles by 2030. In our study, we found that it is possible for LADWP to exclusively use renewable resources to power its system in every hour of the year. What's more, we found that under one of the clean energy pathways analyzed, the transition to 100 percent renewable energy in every hour of the year can occur at no net cost to the system. The resulting report, Clean Energy for Los Angeles, provides a roadmap for how to achieve 100 percent renewables by integrating and harnessing renewable energy more efficiently and investing in additional efficiency, storage, and demand response.
Although the report only focuses on a single city, the results are important and applicable to many other parts of the country. Los Angeles's 4 million residents make the city larger than 22 entire states, while the annual energy served by LADWP is greater than sales in 13 individual states, indicating that if this transition is possible in Los Angeles, it is feasible in other parts of the country as well.
On behalf of the Illinois Office of the Attorney General, Synapse reviewed Commonwealth Edison Company’s (ComEd) proposal for a voltage optimization validation project within the context of ComEd’s formula rate proceeding. Principal Associates Max Chang and Bob Fagan submitted testimony before the Illinois Commerce Commission (Case 16-0259) addressing ComEd’s planned Voltage Optimization Validation Program and its opportunities for data analytics. Synapse’s analysis found that ComEd’s validation study did not adequately demonstrate that the program would address the company’s challenges. Mr. Chang and Mr. Fagan recommended that the Commission direct ComEd to adopt a more comprehensive and robust validation study for voltage optimization. Mr. Chang and Mr. Fagan also recommended that the Commission require ComEd to provide information regarding the development of a long-term plan to fully utilize data gathered from the installation of smart meters and modern distribution infrastructure.
On behalf of Save the Sound, Synapse is comparing recent studies on the need for new and expanded natural gas pipeline infrastructure proposed by Kinder Morgan subsidiary Tennessee Gas Pipeline in Connecticut and surrounding states. Within the context of Connecticut energy demand and climate laws, the team is reviewing and synthesizing the findings of three separate New England natural gas demand reports released in 2015, examining issues related to compliance with Connecticut’s Global Warming Solutions Act, and placing these findings in the context of expected near- and medium-term capacity and demand of natural gas in Connecticut.
Sierra Club retained Synapse to review Dayton Power and Light’s (DP&L) application for approval of an electric security plan (Cases No. 16-0395-EL-SSO, 16-396-EL-ATA, and 16-397-EL-AAM). Synapse’s review focused on DP&L’s proposed Distribution Modernization Rider (DRM) and the value and outlook of the Company’s coal fleet. The proposed DRM would charge ratepayers $145 million per year over seven years. These charges would subsidize risky capital investments in the Company’s coal assets—several of which have been determined by other owners to have value and be unreliable. On behalf of Sierra Club, Tyler Comings submitted testimony to the Public Utilities Commission of Ohio demonstrating the coal fleet’s low value and poor reliability and recommending that the Commission deny the DMR.
Synapse was retained to provide expert witness and consulting services to the Hawaii Division of Consumer Advocacy in a proceeding to develop and review integrated resource plans (IRPs) for three electric companies. Topics include scenario planning, resource modeling, community and stakeholder input processes, and analysis of locally produced biofuels, wind and solar energy opportunities (both distributed and large scale), battery storage, and other renewable energy options. The three major electric companies supplying 95 percent of Hawaii’s electricity are simultaneously facing the need to retrofit or replace existing generation impacted by new environmental regulations and the onset of a very stringent renewable portfolio standard (40 percent by 2030). Imported fossil fuel costs are the primary driver behind high electricity rates and subject Hawaiian residents to rapidly fluctuating prices. Currently all of the Hawaiian Islands operate their electricity systems independently; a major planning issue going forward is interconnecting several of the islands using undersea cables in order to better integrate and manage high levels of variable renewable energy. On behalf of the client, Synapse is reviewing these key issues and addressing how best to meet future constraints and policy goals while minimizing costs to consumers.
Direct Testimony of Rick Hornby Regarding HECO & HELCO’s Application for a Biofuel Supply Contract with AKP
Direct Testimony of Patrick Luckow Regarding HECO & HELCO’s Application for a Biofuel Supply Contract with AKP
Since 2007, Synapse has assisted the Cape Light Compact with various aspects of their participation in the New England Forward Capacity Market (FCM). Project ongoing.
The Massachusetts restructuring law enables municipal aggregators to implement energy efficiency programs with funds raised from all customers through a system benefits charge. More than 13 years ago, Synapse designed the energy efficiency programs that are being provided by the Cape Light Compact, the municipal aggregator on Cape Cod. Since then, Synapse has assisted the Cape Light Compact (the Compact) with energy efficiency plan, annual report, and energy efficiency charge reconciliation filing preparation, including energy efficiency data reporting and analysis and policy support. Energy efficiency data reporting and analysis includes processing of data from the Compact’s database into tables for plans and reports and analysis of the plans and reports, preparation of the exhibits for the energy efficiency charge reconciliation filing, and drafting of memos on key aspects of filings as needed to inform stakeholder review. Policy support includes implementing key outcomes of Massachusetts Department of Public Utility (MA DPU) Orders, developing positions in open dockets, representing the Compact in stakeholder working groups, and providing expert testimony before the MA DPU.
The Cape Light Compact Energy Efficiency Plan Phase II: 2003-2007
Serious, imminent, and irreversible damages to natural ecosystems, infrastructure, agricultural production, and human health make dramatic reduction of greenhouse gas emissions a key priority for communities around the world. Most greenhouse gases are emitted as a result of our use of energy, and the Commonwealth of Pennsylvania is no exception in this regard. Delaware Riverkeeper Network asked Synapse Energy Economics and EQ Research to find a path forward that will enable Pennsylvania to serve its energy needs entirely with clean, zero‐emission renewables by 2050.
On October 20, 2016, Synapse joined EQ Research and Delaware Riverkeeper Network to present a public webinar discussing the report. A recording is available on Delaware Riverkeeper Network's website.
Press Conference: "Envisioning Pennsylvania's Energy Future" Report Release
Envisioning PAs Energy Future (Public Webinar Slides)
In response to the Virginia State Corporation Commission’s questions on evaluation, measurement, and verification (EM&V) methods, Synapse prepared a memo where we reviewed, summarized, and provided recommendations with respect to current EM&V practices in Virginia, national best practices, and emerging practices enabled by the development and adoption of new information and communications technologies. The memo also discussed inputs and recommendations for methodologies to calculate the levelized cost of saved energy. The Virginia Energy Efficiency Council included the memo with its May 25, 2016 comments to the State Corporation Commission in Case PUE-2016-00022.
Synapse is providing expert testimony in an Eversource rate case, with rate design, net metering, and other issues related to distributed energy resources.
Surrebuttal Testimony of Woolf and Whited Regarding Eversource Rate Case [nid:2572]
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 has engaged Synapse and its subcontractor Lexicon Energy Consulting to review 129 Green Community Annual Reports, develop a Progress Report for the program highlighting achievements to date, and analyze and verify energy data for select towns. 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 is providing expert assistance and testimony on behalf of the U.S. Department of Justice in connection with its investigation of potential violations of the Clean Air Act by Ameren Missouri.
Synapse is assisting the Hawaii Division of Consumer Advocacy in an investigation to reexamine the existing decoupling mechanisms for the Hawaiian Electric Companies (Docket 2013-0141). The Hawaii Public Utilities Commission opened this investigation to determine whether the existing decoupling mechanisms, including both the Revenue Balancing Account (RBA) and the Revenue Adjustment Mechanism (RAM), are effectively serving their intended purposes, are fair to the HECO Companies and ratepayers, and are in the public interest. Schedule A of this docket addressed interest rates, tax deferrals, risk sharing mechanisms, baseline projects in RAM, and performance metrics. Schedule B of this docket will address issues concerning the RAM, particularly related to the incentives that the RAM provides or fails to provide, the fair allocation of risk, and ways to increase the efficiency of ratemaking. Synapse is taking a lead role in reviewing and commenting on the development of HECO’s performance metrics associated with Schedule A, and is leading the development of the Consumer Advocate’s statements of position regarding performance incentives in Schedule B, including analysis of how such incentives might interact with the decoupling mechanism.
Synapse is providing technical and expert witness services to the California Office of Ratepayer Advocates in connection with the Long Term Procurement Plan proceeding affecting the three largest investor-owned utilities in California: Southern California Edison, Pacific Gas and Electric, and San Diego Gas and Electric. As part of this project, Synapse conducted modeling of the California ISO (CAISO) area using PLEXOS to assess loads and emissions throughout California based on various California Public Utilities Commission scenarios. Synapse analyzed model inputs, assumptions, forecast projections, and outputs, and examined alternatives including renewable energy integration and retirement scenarios. Synapse’s modeling enabled determination of areas within California that would be capacity constrained.
Reply Testimony of Bob Fagan and Patrick Luckow in Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans
Reply Testimony of Bob Fagan and Thomas Vitolo in Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans
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
Since 2005, Synapse has provided monitoring and representation services for CSG and small companies associated with CSG who have recently become NEPOOL members in the new NEPOOL Alternative Resources sector. CSG was sold to CLEAResult in 2015, and Synapse continues this work with the successor organization. In 2006, VEIC became a NEPOOL member and a Synapse client for whom Synapse provides information and representation services. The Alternative Resources sector is comprised of providers of energy efficiency, renewable, distributed generation, and demand response resources.
Executive Summary Only: Incorporating Energy Efficiency into the ISO New England Forward Capacity Market
NEPOOL’s governance structure allows non-profits and other customer representatives to become voting members. Since 2001, Synapse has provided representation and voting services to non-profit and consumer interest clients. Our clients have included PowerOptions, The Energy Consortium, Harvard, the Union of Concerned Scientists, and MASSPIRG.
Since 2001, Synapse has engaged in NEPOOL and ISO New England committee and working group meetings on behalf of consumer advocate clients in NEPOOL’s End Use sector. Our clients have included consumer advocate offices in Maine, New Hampshire, Connecticut, and Massachusetts. Synapse has provided representation services (voting) in addition to monitoring and information services to all of these NEPOOL clients.
Demand Response Potential in ISO New England’s Day-Ahead Energy Market
Wholesale Natural Gas Prices in New England
Comments on the Procurement of Default Service Power Supply for Residential, Small Commercial, and Industrial Customers in the Commonwealth of Massachusetts
Comments on the Draft 2015 Solar PV Forecast
Comments on 2018 Draft Energy Efficiency Forecast
Synapse is assisting the New Jersey Division of Rate Counsel with analyzing program characteristics of a Societal Benefits Charge (SBC) Credit Program, being implemented in rulemaking Docket No. EO12100940. To this end, Synapse will conduct supporting research, such as reviewing other states’ programs; attend working group meetings; and assist with preparation of comments. Analysis will include consideration of the following: energy reduction thresholds, the costs and feasibility of various options for credit issuance other than a reimbursement check, a SBC Budget to minimize the financial impact of the credit on other Clean Energy Programs, charging applicants an administrative fee to cover program administration costs, how the fee requirement would be administered, and other issues.
Sierra Club retained Synapse to analyze Northern Indiana Public Service Company’s (NIPSO) request for rider on $400 million in capital costs at three coal-fired power plants in Indiana (Bailly, Michigan City, and Schahfer) as they seek to comply with the United States Environmental Protection Agency’s Coal Combustion Residual (CCR) rule and Effluent Limitation Guidelines (ELG). In this docket, NIPSCO seeks to retire four coal-fired units (Bailly 7 & 8 and Schahfer 17 & 18) while retaining three units (Schahfer 14 & 15 and Michigan City 12). Synapse assessed NIPSCO’s economic analysis and supporting “qualitative assessment” and examined whether the retention of the three units would be in the interest of ratepayers, and if the company’s qualitative assessment was reasonably constructed. Dr. Jeremy Fisher filed testimony demonstrating that NIPSO’s ratepayers see $200-$600 million in benefits with the incremental retirement of Schahfer 14 & 15 and that the Company’s application does not support the decision to install retrofits at the units.
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.
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.
Rappahannock Electric Cooperative (REC) has requested approval to increase its fixed access charges for residential customers (from $10 to $20) and small commercial customers (from $28 to $37). Sierra Club retained Synapse to develop testimony that establishes how these increases in fixed charges are inconsistent with fundamental ratemaking principles. In testimony before the Virginia State Corporation Commission, Melissa Whited addressed how the increases would provide inefficient prices signals, reduce customer equity, and reduce incentives for investments in distributed energy resources. Ms. Whited also recommended alternative methods REC could employ to address concerns about revenue sufficiency.
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