Sierra Club retained Synapse to evaluate Kansas City Power & Light's application before the Missouri Public Service Commission to nearly triple customers’ fixed charge from $9 to $25 per month. Synapse conducted analysis and provided expert testimony regarding the impacts of the Company's proposed rate design on efficient price signals, customer equity, and investments in distributed energy resources. Ultimately the Commission rejected the Company’s proposal, approving a new fixed charge of only $11.88.
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Surrebuttal Testimony of Tim Woolf on the Topic of Kansas City Power & Light Company Rate Design Proposal
Synapse worked with Meister Consulting Group to analyze the Clean Energy Plan of Lincoln Electric System (LES), the customer-owner municipal utility for the city of Lincoln, Nebraska, on behalf of Sierra Club. Historically, LES has generated about 85 percent of its electricity from coal-fired power plants. Synapse and Meister used LES’s Clean Energy Plan to develop a set of scenarios examining the bulk power costs (including costs of complying with upcoming environmental regulations) and monthly bill impacts of LES maintaining its coal-focused status quo. The project team also examined alternatives in which LES pursues expanded renewable energy PPAs.
The Massachusetts Department of Energy Resources (DOER) retained Synapse to conduct a low demand modeling analysis. The purpose of the modeling analysis was to consider various gas demand scenarios and to evaluate a range of solutions to meet Massachusetts’ short- and long-term resource needs, considering greenhouse gas reductions, economic costs and benefits, and system reliability.
New England’s energy infrastructure has become increasingly stressed due to various market conditions, leading to near-term supply inadequacy and cost impacts, especially during winter months. DOER sought to compare a range of energy solutions considering greenhouse gas reductions, economic cost and benefits, and system reliability to meet Massachusetts’ short- and long-term energy needs. As such, DOER retained Synapse to evaluate varying solutions for meeting Massachusetts’ energy needs while striking a balance between reliability, cost, and the environment.
As part of the modeling analysis process, Synapse and DOER solicited stakeholder input and feedback at several key junctures. Raab Associates, Ltd. worked with Synapse and took the lead on the stakeholder engagement process. All materials from stakeholder meetings—including notes, slides, and agendas—are made available on this page.
October 15 Stakeholder Meeting Slides
October 15 Stakeholder Summary Notes
October 15 Stakeholder Comments
October 30 Stakeholder Meeting Agenda
October 30 Stakeholder Meeting Slides
Feasibility Study for Low Gas Demand Analysis
October 30 Stakeholder Summary Notes
October 30 Stakeholder Comments
December 18 Stakeholder Meeting Agenda
December 18 Stakeholder Meeting Slides - Updated December 19
December 18 Stakeholder Meeting Slides - Updated January 7
Analysis Workbook: Gas Model (Excel) (updated January 7)
Analysis Workbook: Supply Curve - High Gas (Excel) (updated January 7)
Analysis Workbook: Supply Curve - Low Gas (Excel) (updated January 7)
Analysis Workbook: Supply Curve - Ref Gas (Excel) (updated January 7)
December 18 Stakeholder Comments
December 18 Stakeholder Summary Notes
Massachusetts Low Demand Final Report
Synapse provided technical support to the Minnesota Pollution Control Agency in its estimation of a consumption-based inventory of greenhouse gas emissions for the state.
There are myriad issues to consider when modeling efficiency into IRP. What are the best ways to optimize energy efficiency relative to generating resources? How should efficiency measures be bundled? Can a supply-side approach be an efficient and transparent process for stakeholders? What are the pros and cons for the supply-side optimization approach for energy efficiency versus an approach to place efficiency on the load-side as an exogenous input instead? How does IRP typically incorporate the results of efficiency potential studies? What are the key pitfalls of potential studies as used in IRP?
In “Searching for Best Practices for Modeling Energy Efficiency in Integrated Resource Planning,” presented at the 2015 ACEEE National Conference on Energy Efficiency as a resource, Kenji Takahashi examined the range of options used for incorporating energy efficiency into IRP. Drawing on case examples from various jurisdictions including PacifiCorp, Northwest Power Conservation Council, Tennessee Valley Authority, and Vermont, he recommended best practices for modeling cost-effective energy efficiency in long-term resource plans.
Synapse assisted the Regulatory Assistance Project in developing chapters for the National Association of Clean Air Agencies’ technical document identifying a wide range of technologies, programs, and policies that agencies might employ to comply with EPA’s Clean Power Plan. The document, Implementing EPA’s Clean Power Plan: A Menu of Options, contains 26 chapters, each exploring a different approach to reducing emissions. Synapse prepared Chapter 13: Pursue Behavioral Efficiency Programs and Chapter 14: Boost Appliance Efficiency Standards. The full NACAA Menu of Options can be found here: http://www.4cleanair.org/NACAA_Menu_of_Options.
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.
On behalf of The Alliance for Solar Choice (TASC), Synapse provided expert witness services in a docket opened in Nevada to review NV Energy’s proposal for an alternative net energy metering tariff. NV Energy proposed to establish a new rate class and a new, three-part rate structure for net metering customers. In his direct testimony to the Nevada Public Utilities Commission, expert witness Tim Woolf explained why NV Energy’s proposal is not compliant with SB 374—a state senate bill designed to encourage private investment in renewable energy resources—and why it is inconsistent with ratemaking principles. Mr. Woolf proposed an alternative rate structure that is compliant with SB 374, will prevent cost-shifting between net metering and non-net metering customers, will provide customers with simple, appropriate price signals regarding the value of net metered resources, creates downward pressure on electricity rates, and promotes the development of customer-sited renewable resources in Nevada.
Raab Associates, Ltd. and Synapse prepared a primer on large-scale energy infrastructure issues in 2015 in New England. The primer gives an overview of the current electricity and gas infrastructures in the region, discusses some of the key issues and challenges, and provides an overview of some of the current transmission and gas pipeline proposals. The report was one of four released by the Boston Green Ribbon Commission to provide fundamental information about how the energy supply system works in New England, while highlighting strategies for institutional renewable energy procurement and public sector innovation to reduce greenhouse gases.
Synapse provided expert advice on and analysis of energy efficiency programs offered by New Jersey's Clean Energy Program for the New Jersey Division of Rate Counsel. We reviewed, analyzed, and commented on various energy efficiency-related matters, including the state-administered programs’ designs and budgets, avoided energy supply cost estimates, cost-benefit analyses, energy savings protocols updates, and fiscal year budget proposals. We also reviewed and commented on New Jersey Energy Master Plans, a three-year energy efficiency program plan called the Comprehensive Resource Analysis, and various proposals associated with the new energy efficiency program framework including program delivery structure, program design, performance incentives, and cost recovery.
The Northern Maine Independent System Administration predicted near-term reliability issues in their territory, which is not directly electrically connected to the rest of Maine and the ISO New England. Synapse was hired to assist the Maine OPA in their investigation of the various options being proposed to solve the reliability need, including simple transformer upgrades, additional transmission links to New Brunswick, and large transmission projects that would connect Northern Maine to the ISO New England. Ultimately, a simple and low-cost transformer upgrade project was approved by the ME PUC.
Sierra Club retained Synapse to review Oklahoma Gas & Electric’s application before the Oklahoma Corporation Commission seeking authorization of a plan to comply with the Clean Air Act and to modernize its Mustang plant, and to recover costs for both projects. The filing requested approval of retrofits on Sooner units 1 & 2, conversion of Muskogee units 4 & 5 to natural gas, and construction of new natural gas combustion turbines to replace steam units at Mustang.
Synapse expert witnesses Tyler Comings, Jeremy Fisher, Rachel Wilson submitted direct testimony in this proceeding. Mr. Comings’ testimony focused on the reasonableness of the assumptions used in the Company’s supporting analysis, and how those assumptions impact the net present value of the proposed action. Dr. Fisher discussed the Company’s planning methodology and compared it with best practices in resource planning. Ms. Wilson evaluated the PROMOD and PCI Gentrader modeling performed by the Company and presented the results of her own Gentrader modeling analysis.
The witnesses’ analyses showed that OG&E’s preferred option only advantaged ratepayers in fringe cases, and not at all under reasonable expectations about the future. In December 2015, the Commission denied the Company's application.
Direct Testimony of Jeremy Fisher Comparing the Modeling Performed by Oklahoma Gas & Electric against Best Practices in Resource Planning
Direct Testimony of Rachel Wilson Evaluating the Modeling Performed by Oklahoma Gas & Electric and Presenting Results of Independent Modeling Analysis
Rebuttal Testimony of Tyler Comings Regarding Assumptions in Analysis Supporting OGE Request for Authorization and Cost Recovery of Clean Air Compliance Plan and Mustang Modernization
Rebuttal Testimony of Jeremy Fisher Regarding Oklahoma Gas and Electric Plan to Comply with the Federal Clean Air Act
Synapse assisted the Office of the Auditor General of Ontario during its audit of the region’s electricity power system planning. Synapse provided advice on the key areas the audit team should focus on and best practices in other jurisdictions.
In Utah Docket 14-035-147 and Oregon Docket UM 1712, PacifiCorp proposed to close its Deer Creek coal mine, sell Utah mining assets, and engage in a long-term coal supply contract with the proposed buyer of those assets, Bowie Resource Partners. The resulting coal supply agreement (CSA) would require PacifiCorp’s Huntington Power Station to take, or pay for, a substantial amount of coal through 2029. On behalf of Sierra Club, Synapse reviewed PacifiCorp’s analyses to determine whether the transaction is in the best interest of the Company’s customers. Synapse expert witness Jeremy Fisher assessed that the Company had not determined if the power plant was at risk of being non-economic and had overvalued the benefits of the sale and coal supply agreement. Dr. Fisher recommended that the Commissions of these states hold the Company responsible for signing contracts that allow sufficient optionality, and do not require a long-term commitment to a non-economic resource.
In California Docket A. 15-09-007, PacifiCorp filed a request to authorize the sale of the Utah mining assets on a post-hoc basis. Testifying on behalf of Sierra Club, Jeremy Fisher reviewed the relationship between the mining assets, the long-term CSA, and the mine closure, and determined that the sale of the mining assets could not be separated from the other elements of the transaction, as written, and had not been assessed as a separate entity. In addition, Dr. Fisher discussed the contractual risks encumbent on the Company for executing the contract prior to full regulatory approval, and noted that the Company continued to overvalue the benefits of the overall agreement.
Direct Testimony of Jeremy Fisher Regarding PacifiCorp Request to Authorize Sale of Utah Mining Assets
Synapse prepared a report for the Western Interstate Energy Board that describes how regulators can guide and improve utility performance through the use of performance metrics or through performance incentive mechanisms. From reliability and safety standards to customer engagement, these tools have been widely used and are evolving to provide regulators with new means of ensuring that utilities’ incentives are aligned with the public interest. The report identifies many of the metrics and performance incentives that regulators have used to monitor and evaluate utility performance, as well as emerging metrics and incentives that are being discussed in jurisdictions facing new issues and challenges, such as the integration of distributed energy resources. The report also provides a set of principles and recommendations for regulators based on Synapse’s review of the large amount of literature on these topics and lessons learned from case studies.
Webinar: Guiding Utility Performance
Performance Incentive Mechanisms: Presentation to the Western Interstate Energy Board
Presentation to e21 Initiative: Performance Incentive Mechanisms
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 analyzed the potential for clean alternatives to replace Progress Energy’s Asheville, North Carolina, coal-fired power plant. Specifically, this analysis considered local reliability issues that may be triggered by the retirement of the Asheville plant, the ability of clean alternatives (such as energy efficiency and renewable resources) to resolve those reliability issues, and the comparative costs and bill impacts of clean alternatives versus pollution control retrofits at the Asheville plant. Synapse’s work product discussed the untapped potential for energy efficiency, renewable energy, and demand response in the service territory of the Asheville plant.
Synapse assisted Sierra Club with an analysis of the revenue requirements necessary to install a cooling tower at Wisconsin Public Service Corporation?s (WSPC) Pulliam Units 7 and 8. Rachel Wilson submitted direct testimony to the Wisconsin Division of Hearings and Appeals on total cost estimates for construction and operation of the cooling towers as well as the economic achievability of the cooling towers and the expected impact on electric rates in WSPC?s service territory.
On behalf of Sierra Club, Synapse evaluated the reasonableness of the Midcontinent Independent System Operator’s (MISO) 2015/2016 capacity auction, which resulted in a dramatic price spike for Zone 4 (southern Illinois). Synapse’s analysis found that the auction results were an artifact of the auction construct, and did not accurately reflect actual supply and demand conditions. In particular, Synapse highlighted the fact that counter flows from power exports were not accurately accounted for, and that the threshold for investigating possible market power was inappropriately tied to PJM’s clearing prices. As a result, Synapse recommended that FERC reject the results of the auction and that the flaws in the auction construct be corrected. Following a technical conference on this matter, FERC agreed with Sierra Club and other intervenors that MISO’s method for calculating counter flows and for determining the threshold for investigation of market power were not just and reasonable, and ordered MISO to change its methodologies.
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.
On behalf of Appalachian Mountain Advocates (AMA) and the Southern Environmental Law Center, Synapse analyzed natural gas demand and a 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.
Synapse conducted a literature review of wind and solar integration cost studies and found costs commonly less than $5 per megawatt-hour. Synapse found that despite differences in the types of systems across the country—some composed of much more inflexible coal or nuclear generation than others—costs across systems appear to follow similar bands. Integration costs represent the cost of measures to help meet the incremental needs of the system as more renewable energy is brought online, typically in the operational timeframe. Measures to address these needs include improved coordination between neighboring system operators, increased geographic diversity of wind and solar installations, transmission reinforcements, and demand-side solutions such as demand response and time-of-use pricing. System planners should still conduct their own focused studies on how they will manage renewable resources, but the Synapse review suggests there is no need to put the brakes on further development, as these costs tend to be quite small.
In addition to the report, Synapse prepared a two-page brief on the challenges, solutions, and costs of integrating renewable energy. "Remodeling the Grid: Challenges, Solutions, and Costs Associated with Integrating Renewable Resources" can be found below.
Remodeling the Grid: Challenges, Solutions, and Costs Associated with Integrating Renewable Resources (brief)
Renewables Integration and the Clean Power Plan (slides)
Synapse assisted Conservation Services Group in the design of a Residential Demand Response program using wireless thermostats that would conform to ISO New England requirements for telemetry and performance reporting.
Synapse conducted a technical and economic review of planning studies and analysis made by the City Water, Light and Power (CWLP) of Springfield, IL and its subcontractors, including Burns & McDonnell, regarding the future of CWLP’s coal-fired electric generating units Dallman 31/32. The Synapse team, led by Dr. Vitolo, found that the operation of these units lost the city at least $41 million between 2008 and 2013, and that the prudent course of action for CWLP would be to prepare for their imminent retirement.
Synapse provided testimony on behalf of the Office of the Ohio Consumers' Counsel regarding AEP Ohio’s request to pass through to its customers the costs and revenues of 20 coal units. Customers would bear these costs until the scheduled retirement dates for the plants, which currently range from 2033 to 2051. Expert witness Sarah Jackson examined the utility's environmental compliance plan and assessed the related potential financial risks that the coal units posed to customers.
In April 2008, Brockton Power Company filed a Major Comprehensive Plan Application (MCPA) for a 350‐megawatt combined cycle fossil fuel-fired electric generating facility in Brockton, Massachusetts. After the Massachusetts Department of Environmental Protection (DEP) issued its conditional approval of the MCPA, residents of Brockton and surrounding areas appealed the permit, arguing that the power plant and DEP had failed to demonstrate that the benefits outweigh the burdens, as required by Massachusetts law. Synapse reviewed Brockton Power’s cost-benefit analyses, Economic Development Research Group, Inc.’s economic assessment, and DEP’s cost-benefit analyses of the proposed project. Synapse submitted direct testimony to the DEP presenting the results of this review and explaining the appropriate way to assess the economic impacts of a large industrial project such as an electric generating facility.
Supplemental Testimony of Elizabeth A. Stanton on the Economic Analyses of a Proposed Brockton Power Company Generating Facility
Elizabethtown Gas filed a petition in April 2015 to the New Jersey Board of Public Utilities for approval of a new energy efficiency program budget. The budget included the continuation of Elizabethtown’s existing three energy efficiency programs and the implementation of two new programs for a four-year period beginning September 1, 2015 through August 31, 2019. On behalf of the New Jersey Division of the Rate Counsel, Synapse issued discovery requests, analyzed and reviewed the petition and discovery responses, and provided support to the client during settlement discussions. Primary issues included energy costs and savings assumptions, cost-benefit analyses, marketing budgets, load building programs, and demonstration of incremental program benefits when more than one efficiency program targets the same market. Under the settlement, the Company agreed to withdraw the April 2015 petition, and to continue to extend the current programs until the end of 2016 with the remaining budget.
As a subcontractor to Eastern Research Group, Synapse provided consultation services to the U.S. EPA in which we reviewed and assessed numerous energy efficiency programs across the United States on a variety of topics including, but not limited to: (a) costs of saved energy; (b) energy savings at the sector and portfolio levels; (c) annual savings ramp-up rates; (d) energy efficiency measure life; (e) energy savings decay profiles; (f) participant costs vs. program incentive; (g) energy efficiency potential; and (h) energy efficiency portfolio standards.
Synapse provided technical support including expert witness testimony concerning the results of Southern California Edison’s (SCE’s) Request for Offers for local capacity resources (LCR) in the Western LA Basin area. SCE’s procurement included energy storage resources at both the bulk, wholesale level (connected at 230 kV), and at a selection of locations on the distribution grid (on-site at small commercial and industrial buildings), including thermal storage procurement. Synapse reviewed the utility’s testimony submitted to the California Public Utility Commission (CPUC), in light of the 2012 Long-Term Procurement Plan decision on local capacity resource need in the LA Basin, as well as other filings and CPUC decisions concerning the type of resources required to be secured by SCE. Synapse also analyzed SCE’s optimization mechanism for choosing storage resources, with a focus on interconnection and tariff energy charge issues and the allocation of storage benefit across energy, capacity, and ancillary service markets. In testimony, Synapse supported the acquisition of a larger level of storage resources than selected by SCE, supported by evidence that the cost/benefit analyses of SCE indicated a net economic benefit for the system if greater levels of energy storage were procured.
Synapse was retained by Sierra Club to review the integrated resource plans (IRP) of three utilities in Louisiana: Entergy, SWEPCO, and Cleco. For SWEPCO and Cleco, Synapse identified which elements of the IRP were improvements over past plans and which areas needed continued improvement. Sierra Club requested that Synapse evaluate Entergy’s IRP in more detail. Synapse reviewed the results of Entergy’s 2015 draft IRP, provided feedback on the Company’s modeling inputs and methodology, and recommended improvements for future planning documents. After reviewing the information Entergy made publicly available during the stakeholder engagement process, Synapse identified several concerns, including a flawed modeling structure, unreasonable assumptions, underestimation of demand-side management potential and benefits, and general lack of transparency.
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