Synapse reviewed assumptions in Delmarva Power and Light’s benefit-to-cost analysis of its Advanced Metering Infrastructure (AMI) Initiative. Max Chang submitted testimony on behalf of Maryland OPC demonstrating that, due to unreasonable assumptions, DPL overestimated the benefit to cost ratio of the AMI program for the 2015-2024 period. Mr. Chang recommended that the Commission disallow $34 million in order to protect ratepayers.
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On behalf of the Office of the People's Counsel for the District of Columbia (OPC), Synapse evaluated several aspects of distributed generation in Washington, DC. This project consisted of three research topics. First, Synapse researched and offered recommendations regarding policies that can sustainably support the development of distributed generation in the District, while avoiding adverse consequences. Second, Synapse assessed the technical and economic potential for distributed generation in the District, particularly solar photovoltaics (PV). Finally, Synapse conducted a benefit-cost analysis of solar in the District.
OPC Reply Comments Regarding Pepco Comments on Value of Solar Study
Synapse was retained by Earthjustice to draft a whitepaper discussing grid resiliency issues in the context of the United States Department of Energy (DOE)’s “grid resiliency pricing rule” proposal. DOE’s proposal directed the Federal Energy Regulatory Commission (FERC) to design rules that would guarantee full recovery of costs for all generating units operating in competitive wholesale markets with 90 days of fuel supply on-site (conventionally understood to refer to nuclear and coal-fired units). Synapse’s whitepaper discusses several key problems associated with this proposal: first, the authorities in charge of the nation’s wholesale energy markets (including FERC itself as well as ISO/RTOs and state agencies) have devoted substantial efforts to increasing the reliability and resiliency of the grid system and have reasonable, market-based approaches for accomplishing this goal. Second, fuel supply disruptions have not historically been a significant cause of service interruptions. Third, coal units in particular are vulnerable to both fuel supply disruptions and other failures during extreme weather and temperature events, and have demonstrated decreasing reliability over time. Synapse’s whitepaper was filed under FERC docket RM18-1-000 in support of comments submitted by Earthjustice, Environmental Defense Fund (EDF), Natural Resources Defense Council (NRDC), Sierra Club, Sustainable FERC Project, the Union of Concerned Scientists (UCS), the Center for Biological Diversity, the Environmental Law and Policy Center, the Southern Environmental Law Center (SELC), Conservation Law Foundation (CLF), Environmental Working Group, and Fresh Energy.
A coalition of organizations including Michigan Environmental Council, Sierra Club, and NRDC, hired Synapse to review and provide expert testimony regarding DTE Electric's application for a Certificate of Necessity to construct a 1,100 MW Natural Gas Combined Cycle plant. Synapse experts Avi Allison and Bob Fagan filed testimony critiquing DTE's assumptions regarding renewable and market resource alternatives to its proposed gas plant, and demonstrating that DTE would likely save its customers money by investing in a combination of energy efficiency, renewable energy, and market purchases rather than building a new gas plant.
Direct testimony analyzing overall need and critiquing a DTE Energy proposed natural-gas fired combined cycle plant in Michigan
Rebuttal testimony analyzing overall need and critiquing a DTE Energy proposed natural-gas fired combined cycle plant in Michigan
The Dakota Access pipeline, proposed in 2014, was designed to carry crude oil from the Bakken oil field in western North Dakota, through South Dakota and Iowa, to a pipeline hub in southern Illinois. The final stages of construction, not yet completed, have become the subject of a wide-ranging controversy involving multiple environmental, legal, cultural, and economic issues.
In February 2017 Synapse produced a report based on research performed for Fredericks Peebles & Morgan LLP, attorneys for the Cheyenne River Sioux, addressing one dimension of the controversy: the economic impacts of completing the Dakota Access pipeline.
As a continuation of previous work, Synapse provided NS UARB with consulting services on energy efficiency issues. Specifically, Synapse provided technical support and analysis with respect to rate and bill impacts, low-income program participation and performance, methodology to determine program incentives, and benefits of location-specific efficiency targeting.
Reply Comments on CLEAResult EfficiencyOne Incentive Setting Methodology
Comments on Revised CLEAResult EfficiencyOne Incentive Setting Methodology
Comments on EfficiencyOne 2016 Rate and Bill Impact Analysis
Comments on Efficiency Nova Scotia 2017 DSM Progress Report
The Maryland Office of People’s Counsel retained Synapse to review the independent assessment of two offshore wind applications before the Maryland Public Service Commission in Case 9431. The two proposals under consideration are from US Wind for a 248 MW wind farm and Deepwater Wind for a 120 MW wind farm. Maryland's Offshore Renewable Energy Credit legislation establishes administrative thresholds for each offshore wind application and evaluation criteria for the Commission to use in its review. Synapse reviewed the findings, inputs, and calculations of the independent assessment and the two applications to provide recommendations regarding the renewable energy credit payments, ratepayer impacts, economic impacts, and net benefits attributed to each proposed project. Max Chang submitted testimony on behalf of MD OPC in March 2017.
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 also identified strategies that are effective across towns and made recommendations to continue to advance and improve the program. Synapse developed the Green Communities Program 2016 Progress Report, available here, and provided updated analysis for 2017 and 2018.
Synapse reviewed the analysis conducted by Idaho Power Company (IPC) in support of its 2017 Integrated Resource Plan. In comments submitted on behalf of Sierra Club, Synapse identified concerns including a lack of rigorous modeling, the selection of an illegal resource plan, under-statement of future coal unit costs, and the lack of rigorous evaluation of the economic status of existing IPC coal units. Synapse recommended that IPC conduct optimization modeling in future IRPs, and fully assess the status of its Jim Bridger coal plant with respect to reasonable alternatives.
Sierra Club Final Comments on Idaho Power Company's 2017 IRP
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
Maine’s low-income residents, like those throughout the United States, face higher energy burdens (i.e., spend proportionally more of their budgets on electricity and heating fuels) than other residents. While Maine has addressed this disparity through various measures for decades, the state and other relevant entities can act more effectively by gaining a better understanding of how and where this disparity tends to strike. With this in mind, the Maine Office of the Public Advocate commissioned a study by Synapse Energy Economics (Synapse) to shed light on the energy burdens faced by Maine’s residents. The resulting report describes Synapse’s findings on energy use in homes. We relied on various publicly available federal data sources such as the U.S. Department of Energy’s Low-Income Energy Affordability Data (LEAD) tool. We assessed differences in home energy expenditures by income bracket, by home ownership status, by type of heating fuel, and by county. The analysis reveals that Maine’s low-income households have a high energy burden: The average (mean) home energy burden for low-income households is 19 percent. On average, low-income households in the state far exceed the thresholds for the various definitions of energy poverty (generally starting with a minimum energy burden in the range of 6 to 10 percent of household income). In comparison, we find in our analysis that the average home energy burden for all Maine households is 6 percent.
Madison G&E is seeking to build 66 MW of wind in Iowa in Docket 3270-CE-127. Synapse provided expert testimony on behalf of Sierra Club regarding the Company's assumptions and modeling. Key questions included whether or not larger turbines or simply a larger project would have been more economic.
Synapse reviewed the Maritime Link Interim Cost Assessment. Specifically, Synapse analyzed the value of the Maritime Link asset to ratepayers given costs associated with a delay in delivery of energy via the Maritime Link. Further, Synapse assessed if the Maritime Link Project, approved by NS UARB in 2013, would be “used and useful.” Bob Fagan and Tyler Comings submitted joint direct testimony on these issues to the NS UARB.
Synapse provided technical assistance and expert testimony on behalf of Conservation Law Foundation regarding the grid modernization plans of Eversource, National Grid, and Unitil in Massachusetts Department of Public Utilities dockets 15-120, 15-121, and 15-122. Synapse reviewed the methodologies and assumptions used by the companies in their plans. Synapse also assessed the extent to which the proposed plans meet the Department’s objectives for grid modernization, with particular focus on the plans’ incorporation of distributed energy resources as a key contributor to grid modernization.
Maritime Electric finalized its Open Access Transmission Tariff. Synapse provided technical support to the Prince Edward Island Regulatory and Appeals Commission to assess the tariff's compliance with FERC open access principles.
Sierra Club retained Synapse to review the draft parameters for Michigan’s impending IRP process proposed by the state’s governing agencies. Synapse found that, while most of the parameters were appropriate and up to standards for IRPs, Synapse identified a few areas in which changes could be beneficial for both planning participants and customers impacted by the IRP. Synapse’s comments to the Michigan Public Service Commission Staff outlined such changes, for example clarifying the relationship between the IRP process and the transmission and distribution and fuel planning processes; defining how utilities should select a preferred scenario; and modifying some modeling assumptions to better align with utility planning and ensure a more accurate, detailed, and robust analysis.
Synapse is assisting the Michigan Public Service Commission in the development of a strategy to comply with EPA’s Clean Power Plan. To support the state planning process and evaluate compliance options, Synapse has built a detailed representation of the regional electrical system in System Optimizer, a utility-scale capacity expansion model. The model optimizes specific electric generating unit build and retire decisions, cost-effective energy efficiency, unit retrofit decisions, emissions trading programs, and emissions targets through 2034. Synapse developed Michigan-specific inputs to the model in collaboration with staff of the Public Service Commission, the Michigan Department of Environmental Quality, and the Michigan Agency for Energy. Synapse will use the model to test compliance plans developed by the joint agencies and stakeholders, including Michigan utilities, consumer, industry, and environmental groups.
On behalf of the World Bank, Synapse developed a transparent, user-friendly, Excel-based model that can estimate the greenhouse gas (GHG) emission reductions resulting from changes to electric-sector policies. It attempts to produce a reliable, documented estimate of GHG savings attributable to the initiative, suitable for use in international analysis and crediting of GHG reductions. This software tool is a power sector model, designed to examine effects of policies such as price changes, subsidies, and emissions taxes on the operation of an existing electric system. The current, first implementation of the model developed with stakeholder involvement from agencies in Morocco and is based on data and policy options that are specific to Morocco. The software is designed to be easily updated as new data become available. It is also readily adaptable to other countries in future implementations. Development of the tool itself, a user manual, and an internal report demonstrating the tool’s abilities were finalized in Spring 2018.
Synapse worked for the National Efficiency Screening Project (NESP) to develop a National Standard Practice Manual (NSPM). The purpose of the NSPM is to improve the way that utility customer-funded electricity and natural gas energy efficiency resources are evaluated for cost-effectiveness throughout the United States, and to inform decision-makers regarding which efficiency resources are in the public interest and what level of investment is appropriate. The NSPM updates and expands upon the California Standard Practice Manual and will provide the principles, concepts, and techniques for sound, unbiased evaluation of energy efficiency and other demand side resources. Synapse's primary role was as the lead technical consultant and was responsible for the overall drafting of the manual, managing the Drafting Committee of five experts, and incorporating input from the Review Committee.
Synapse is providing the Division of Public Utilities and Carriers with technical support for the National Grid rate case. The project includes expert testimony and addresses issues related to performance incentive mechanisms, multi-year rate plans, advanced metering, rate designs, and electric vehicles.
Testimony of Tim Woolf and Melissa Whited on National Grid Rate Case
Direct Testimony of Tim Woolf and Melissa Whited on Power Sector Transformation Proposals
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.
Advanced Energy Economy Institute retained Synapse to review earnings adjustment mechanisms proposed by National Grid in New York. Earnings adjustment mechanisms provide performance incentives for utilities that better align utility performance with regulatory goals. Tim Woolf and Melissa Whited filed testimony before the New York Public Service Commission that provided recommendations regarding which performance incentive mechanisms to approve, as well as appropriate financial incentive allocations.
Synapse also prepared a report on state-wide performance incentive mechanisms for New York. The report examines some of the strengths and weaknesses of each of the three types of performance incentive mechanisms: outcome-based, program-based, and action-based. Because current efforts to implement performance incentive mechanisms in New York focus on outcome‐based mechanisms, the report provides an in-depth analysis of outcome-based performance incentives.
Rebuttal Testimony of Woolf and Whited on National Grid EAM Proposal
Earnings Adjustment Mechanisms to Support New York REV Goals
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.
Review of the 2017 Nova Scotia Load Forecast.
Comments on NSPI Reply Evidence
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.
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 in 2017. 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. The evidence 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. To address deficiencies identified by Ms. Napoleon and others, NSPI withdrew its initial AMI application and stated its intention to submit an amended filing.
In October, 2017, NSPI submitted an application to implement AMI throughout its service area. The application requested Board approval of a capital work order for $133 million to replace about 495,000 conventional meters with smart meters over the period 2018 to 2020. In early 2018, Alice Napoleon submitted evidence on behalf of the NSUARB regarding NSPI's proposal. Specifically, the evidence considered: 1. cost effectiveness of the proposal, including the magnitude of and support for claimed benefits such energy savings associated with critical peak pricing; 2. the reasonableness of allowing a return on the conventional meters to be replaced; and 3. coordination with the energy efficiency utility, EfficiencyOne, to enable benefits of the meters to be realized. In response to this evidence, NSPI submitted a sensitivity analysis to more fully consider the downside risks. The Board approved NSPI’s proposal subject to conditions but disallowed a return on the existing meters.
Synapse submitted formal comments to the Department of Energy regarding its use of the Federal Power Act to allow continued operation of the Yorktown coal units in Virginia. Dr. Ariel Horowitz drafted the comments, which focused on the lack of a sound alternatives analysis, the imprudence of relying on elderly and inefficient coal units for reliability purposes, and the need for a near-term plan to retire the units.
Utah Clean Energy engaged Synapse to review Pacificorp’s proposal before the Utah Public Service Commission to alter its net metering compensation mechanism for residential customers with distributed generation. Melissa Whited submitted testimony to the Commission critiquing multiple aspects of the Company’s proposed distributed generation rate design. Synapse’s analysis of the bill impacts showed that the Company’s proposed changes would have a substantial negative impact on the adoption of residential solar. The proposed distributed generation tariff would essentially eliminate the economic advantage to residential customers of installing distributed generation. Further, the Company’s plan to move these net-metered customers into a separate rate class would increase costs to non-net metered customers. Whited also testified that demand charges are not appropriate for residential customers. Tim Woolf submitted testimony addressing the Company’s flawed cost-benefit analysis. Based on Synapse’s finding that the benefits of the Company’s existing net metering program surpass the costs, Mr. Woolf recommended that the Commission not approve the proposed changes.
Direct Testimony of Tim Woolf Regarding Pacificorp Net Metering
Rebuttal Testimony of Tim Woolf Regarding Pacificorp Net Metering
Synapse provided expert testimony in the Eversource rate case regarding the Company's proposed performance-based regulation (PBR) proposal and rate design modifications for net-metered customers. Synapse's rate design testimony addressed whether the Company had demonstrated a need for a Monthly Minimum Reliability Charge (MMRC), and whether the proposed MMRC would comport with the rate design goals of efficiency, simplicity, and continuity.
Surrebuttal Testimony of Woolf and Whited Regarding Eversource Rate Case
Supplemental Testimony of Woolf and Whited Regarding Eversource Rate Case
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)
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